Bristol is in the throes of preparing a new Local Plan – this is the strategic plan for development in Bristol for the next 10-15 years. It sets the policies applicable to particular sites that will then guide decisions if planning applications are made. Previously, Stoke Lodge has been protected as ‘Important Open Space’ under the Local Plan. But in the new Plan, the Council wants to use new designations for open space, including ‘Local Green Space’ as set out in the National Planning Policy Framework (NPPF).
The NPPF states that the Local Green Space designation should only be used where the green space is:
a) in reasonably close proximity to the community it serves;
b) demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and
c) local in character and is not an extensive tract of land.
BCC’s draft Local Plan is currently undergoing a long and detailed examination process headed up by expert planning inspectors, whose job it is to ensure that the Plan is ‘sound’. As part of that, public hearings are being conducted during which individuals/groups can have their objections heard, and on 27 March it was the turn of the Green Infrastructure policies, including GI1 (Local Green Space) and GI2 (Reserved Open Green Space). Both LGS and ROGS are protected open spaces, so what’s the difference?
- LGS is, like greenbelt land, ‘protected from development which would harm the green space’s character, role and appearance’.
- In the case of ROGS: ‘Development on these spaces is generally not allowed, however where a space can be seen to be no
longer fulfilling its open space function and its loss would not lead to a deficiency of open space, development will be permitted.’
So it’s surprising, isn’t it, that Cotham School turned up to the examination hearings to make a case that Stoke Lodge should not be protected as LGS (playing fields forever) but should instead be designated as ROGS. The only reason for making that objection would be so that potentially, in future, the land might be available for other development – something that Cotham School has always maintained is absolutely the furthest thing from its mind, honestly.
That wasn’t their pitch at the hearing, though. Instead, the Headteacher, Jo Butler, and a property consultant who had written an 11 page submission, claimed that:
- LGS designation could result in the loss of school playing fields. Repeatedly, the Inspector asked “How?” – planning policy designations don’t change the use or function of a site.
- LGS designation would be discriminatory against young people. Again, the Inspector asked “How?” – LGS designation won’t stop Stoke Lodge being used as a playing field.
- Stoke Lodge is the only playing field proposed as LGS in the draft Local Plan – this is simply not true; there are four playing fields with this proposed designation and playing field use is actually contemplated within the definition in the NPPF framework (see above).
- The school wasn’t consulted about the designation… or was it?
We want to clarify this last point. BCC ran a separate consultation about the introduction of new open space policies in 2019. Cotham’s Headteacher Jo Butler said of this consultation that:
- the school wasn’t consulted on the change of use [the Inspector pointed out that it wasn’t a change of use];
- lots of Cotham pupils don’t have access to green space [the Inspector pointed out that LGS designation actually protects green space – that’s the point of it]; and
- she thought the designation had come about because of “pressure from campaigners who somehow knew about this consultation”.
Let’s take a look at what Ms Butler apparently thinks was some kind of cloak and dagger consultation exercise that the school was not let in on. It was actually a public consultation (the consultation document is here) and multiple in-person events were also held. The response document, published in September 2019, lists the respondents. There were 968 individuals and organisations who responded to the consultation, from all over the city. And in relation specifically to whether Stoke Lodge should be designated ROGS or LGS, there were 203 responses. The consultation response also notes that a petition was received for the designation of Stoke Lodge as an area of LGS, signed by 1,574 people.
But what’s this? Respondent no. 489 to the consultation, who commented on the designation for Stoke Lodge, was… Cotham School!
Not only did Cotham School know about the consultation, but it responded to it (and we can only assume that Ms Butler knows what is done in the name of her school). So why did she repeatedly claim that the school had not been consulted? Why did her property consultant say the same, both in his written report and at the hearing? Surely there was no intention to mislead the Inspector? None of Cotham’s objections to the designation of Stoke Lodge hold water, and the claim about not being consulted is obviously and provably untrue.
The key point about the LGS designation is that a site must be ‘demonstrably special to a local community’ and ‘hold particular local significance’. To which we say: show us another site for which the local community has provided evidence to support two court cases, three TVG applications and four public rights of way; for which the community has raised thousands and thousands of pounds to maintain and protect the land and open access to it for all, for ever; for which 1,574 people signed a petition supporting LGS designation. Stoke Lodge is clearly ‘demonstrably special’ – here’s the video we produced at the time:
Designation as LGS doesn’t affect the use of the field as playing fields at all (neither does village green status). It does mean that if Cotham School has ambitions to develop the field for other purposes, it will have to give them up. If it has no such ambitions, then it has no need to object to LGS status. And yet Cotham School’s senior leadership turned out in force last Thursday to make their objections. Let the reader understand.
We need to talk about Stoke Lodge 