Mr Daniel Stone
St Georges Road
Date: 30 April 2010
Dear Daniel Stone
RE: Planning application: 10/00812/P. Outline Application for redevelopment of
Bristol City Football Club for relocated Sainsbury’s food store, petrol filling station
with car wash, car park and associated works
I am writing to express some concerns that I have in relation to the above planning
application. It is an explicit stated aim of Bristol City Council, Bristol Local Strategic
Partnership, and NHS Bristol, that they wish to achieve city planning and design which is
sustainable and which promotes health for local citizens. There is considerable and
growing evidence that health of people in Bristol, and in the UK more widely, has been
and is being negatively impacted on by certain social trends during the last four decades.
These same trends also contribute to high ‘per capita’ greenhouse gas emissions and to
high dependence on fossil fuels. High dependence on food and transport systems that
require intensive fossil fuel use also makes us vulnerable to major disruptions from the
impacts of fossil fuel depletion. Key amongst the social trends that are causing negative
impacts on health, and vulnerability for the future, are;
a) Increasing car-dependency with resulting loss of ordinary physical activity as part
of everyday life, and loss of local ‘walkable’ access to necessary services and
b) Increasing promotion, by the food industry, of cheap convenience foods that are
high in fat, salt, sugar and additives, and which undermine normal patterns of
healthy eating based on preparation from fresh ingredients. This is bad for health
and is unsustainable in the face of climate change and fossil fuel depletion.
Below are listed five key documents which set out the commitment of Bristol City Council
and Bristol Partnership to ensuring a sustainable and healthy future for Bristol citizens
through the achievement of carbon reduction, the creation of walkable neighbourhoods
with local access to retail and the creation of a transport approach that makes public
transport combined with walking and cycling as the easy normal choice.
• The Bristol 20:20 plan, Bristol’s Sustainable City Strategy
• 1997 Adopted Bristol Local Plan – Saved Policies
• Bristol European Green Capital bid brochure, January 2009
• Bristol City Council Carbon Reduction and Energy Security Framework 2010
• Building a Positive Future for Bristol after Peak Oil, Bristol Partnership, October
• Bristol City Council’s Food Charter, March 2010
The proposal (application 10/00812/P) to demolish one superstore, and to replace it with
a larger superstore less than half a mile distant, runs counter to the aims of carbon
reduction and health improvement for the following reasons;
• Very significant carbon emissions will be associated with the demolition and
rebuild. It would be more carbon-efficient to use the Ashton Gate site for
residential development instead of moving the Superstore, and replacing it with
residential development. Planning Policy Statement 1 sets out the overarching
aim of making prudent use of resources, and can be taken as material to
individual planning decisions. The recent legal judgement by Lord Justice
Carnworth (26 March 2010 London Borough of Hillingdon and Ors v Secretary of
State for Transport) makes it clear that it is not acceptable to disregard the 2008
Climate Change Bill in reaching planning decisions.
• The proposed new Superstore will be very substantially larger, selling a wider
range of goods. This relocation and expansion can only be economically viable if
it attracts substantial trade away from other existing and potential retail outlets
throughout South and South-Western Bristol. This concentration of trade onto the
Ashton Gate site will therefore reduce local neighbourhood access to fresh food
throughout South Bristol and South-Western Bristol, it will suppress local retail
business development throughout South and South-Western Bristol, and it will
increase car-dependency for shopping. All three of these factors are bad for
health now and in the future, and are bad for sustainability.
• The knock-on impacts of the expanded Superstore, expanded car park, and
highway alterations to accommodate the extra car trips, will be an additional
negative impact on health because it will suppress the development of walking,
cycling and play streets that would otherwise be possible in the local area, and it
will have a negative impact on air quality and noise pollution.
On these grounds I therefore recommend that the planning permission be refused.
Should it be minded to approve the application then I believe it is necessary to conduct a
Health Impact Assessment for the proposed development.
If even in the light of a Health Impact Assessment, it is minded to approve the application
then I would like to advocate that Sainsburys be asked to explore a completely new and
innovative model of store design which puts sustainability and health as priorities.
This would require that walking, cycling and public transport be the key mode of travel for
customers, and that retail of minimally packaged local, seasonal produce, be
incorporated into the design. This would require considerable creativity and innovation
and could set Sainsbury’s on a path to become a pioneer in provision of healthy
sustainable food for local people.
Dr Hugh Annett
Director of Public Health
NHS Bristol and Bristol City Council
Cc Marcus Grant – Chair of Healthy City Group