5 planning arguments with ‘material weight’ 

We know you will have your own thoughts and feelings about the proposal to turn the former Wetherspoons, Bingo Hall and Granada Cinema into a massive HMO, but here are 5 relevant planning arguments that will add material weight to your objection.

Material weight is important because it gives councillors and planners ‘material‘ reasons to reject the application. In other words, objections that the Council really should take notice of!

So, pick one or more of the five below to copy and paste the technicalities into the Bristol Planning Portal, the website where you submit your objectionsADDING TO OVER 1200 ALREADY REGISTERED.

These material arguments are to help you backup your own reasons for objection. Please do write your own thoughts in your own words, of course as it’s important for your individual thoughts and concerns to be heard.


1. If you have general concerns about the Landrose proposal

You can copy and paste the below paragraphs and then write your own thoughts about this in your own words.

Bristol City Council has sought to designate the Church Road area that the Property is located in as a “Primary Shopping Area” under site ref PSA0017 and as a “Town Centre” under site ref CEN0032. 

The proposed removal of an existing community social space would have a negative impact on the wellbeing of the local people already living in the area, and that this would not comply with Policy DM5, which require development proposals to provide equivalent or better replacement facilities and to avoid the loss of community facilities or infrastructure. Policy DM5 2.5.3 states that “Community facilities include all uses, commercial or non-commercial, that provide a social or welfare benefit to the community”, which clearly applies to what is the largest social space on Church Road.

Additionally, the proposed HMO scheme fails to provide parking for its residents which could conceivably number 88 people across 44 beds, and this would lead to increased traffic and parking problems in the local area, which would not comply with Policy DM2.

“Proposals involving the loss of community facilities land or buildings will not be permitted unless it is demonstrated that the loss of the existing community use would not create, or add to, a shortfall in the provision or quality of such uses within the locality or, where the use has ceased, that there is no need or demand for any other suitable community facility that is willing or able to make use of the building(s) or land, and appropriate replacement community facilities are provided in a suitable alternative location. ” (Policy DM5: Protection of Community Facilities). 

“Proposals for the conversion of existing dwellings or construction of new buildings to be used as houses in multiple occupation will not be permitted where the development would harm the residential amenity or character of the locality as a result of levels of on-street parking that cannot be reasonably accommodated or regulated through parking control measures” (Policy DM2: Residential Sub-divisions, Shared and Specialist Housing)


2. If you have specific points to make about HMO concentration and lack of parking provision

You can copy and paste the below paragraphs and then write your own thoughts about this in your own words.

The proposed change of use to an HMO scheme would push the HMO density in the area to levels that are beyond the Local Development Plan which requires developments to respect the character and context of the local area in terms of density, scale, and form, and to avoid inappropriate developments that harm the character and appearance of the area.

The amount and concentration of so many HMOs in one place cannot be considered acceptable development as it does not meet the needs of the local area. 

The Landrose proposed development does not provide adequate parking provision to meet the needs of its residents. The Lambeth Parking Standard should be used to inform new development proposals and the provision of parking for residents, visitors and service vehicles.

The lack of parking for up to 88 tenants (44 double bed HMO) and the agreement that Landrose suggest they will force tenants to sign regarding car ownership, is fundamentally unacceptable for this type of development and would be legally unenforceable.

By failing to meet the Lambeth Test criteria, the development should be considered unsustainable and not in compliance with local planning policies. 

There is no suggestion of accessibility for people with disabilities and no disabled parking provision.

Relevant policies:

Policies BCS3, BCS5, BCS7, BCS8, BCS17, BCS18, of the Core Strategy

Policies DM2 and DM14 of the Site Allocations and Development Management Policies

The majority of the HMO SPD

Paragraphs Questions 1.2 and 1.3 of the Urban Living SPD


3. If your main concern is for the protection of community facilities

You can copy and paste the below paragraphs and then write your own thoughts about this in your own words.


DM5 states that: 

“Proposals involving the loss of community facilities land or buildings will not be permitted unless it is demonstrated that the loss of the existing community use would not create, or add to, a shortfall in the provision or quality of such uses within the locality or, where the use has ceased, that there is no need or demand for any other suitable community facility that is willing or able to make use of the building(s) or land”

The Landrose proposal clearly does create the above scenario. Need and demand has been demonstrated consistently and in volume by the Save Redfield Cinema Campaign and its supporters: A 10,000 strong petition to have the site listed as Asset of Community Value, >980 objections to the first set of (near identical) plans submitted by Landrose, 2600 Facebook group members, 7 well attended public consultations, a successfully defended ACV listing.

DM5 also states

“Proposals involving the loss of community facilities land or buildings will not be permitted unless it is demonstrated that the building or land is no longer suitable to accommodate the current community use and cannot be retained or sensitively adapted to accommodate other community facilities”

There is no question at all that the building could easily be retained and adapted to meet the needs and demands of the community with a more sympathetic developer.

And finally in DM5 

“Proposals involving the loss of community facilities land or buildings will not be permitted unless it is demonstrated that the community facility can be fully retained, enhanced or reinstated as part of any redevelopment of the building or land; or Appropriate replacement community facilities are provided in a suitable alternative location”

The Save Redfield Cinema Campaign team has repeatedly demonstrated it has funding options, potential buyers and developers who are willing to develop the site in keeping with the community wishes expressed at several public consultations held by the campaign and UWE MA Architecture programme.

In relation to the most recent use as a Wetherspoons public house: DM6: Public Houses

“Proposals involving the loss of established public houses will not be permitted unless it is demonstrated that: (i) The public house is no longer economically viable; or (ii) A diverse range of public house provision exists within the locality. Where development is permitted any extensions or alterations should not harm the identity or architectural character of the public house”.

There is no evidence to suggest that the pub was not viable. Wetherspoons were still making a profit on the site but restructuring their portfolio at a national level. Given the site had not been refurbished in a number of years it is more likely that this was the reason for the sale.


4. If you have issues with the overall quality and scope of the Landrose proposal

You can copy and paste the below paragraphs and then write your own thoughts about this in your own words.

The Landrose proposal provides little to none of the requirements in BCS21: Quality Urban Design


“New development in Bristol should deliver high quality urban design. Development in Bristol will be expected to: 

  • Contribute positively to an area’s character and identity, creating or reinforcing local distinctiveness.
  • Promote accessibility and permeability by creating places that connect with each other and are easy to move through. 
  • Promote legibility through the provision of recognisable and understandable places, routes, intersections and points of reference.
  • Deliver a coherently structured, integrated and efficient built form that clearly defines public and private space. 
  • Deliver a safe, healthy, attractive, usable, durable and well-managed built environment comprising high quality inclusive buildings and spaces that integrate green infrastructure.
  • Create a multi-functional, lively and well-maintained public realm that integrates different modes of transport, parking and servicing. 
  • Enable the delivery of permanent and temporary public art. 
  • Safeguard the amenity of existing development and create a high-quality environment for future occupiers. 
  • Promote diversity and choice through the delivery of a balanced mix of compatible buildings and uses. 
  • Create buildings and spaces that are adaptable to changing social, technological, economic and environmental conditions

The Landrose proposal also offers no accessibility for people with disabilities and no disabled parking provision.

The Landrose proposal also omits a light study: See Policies BCS14 and BCS23 of the Local Development Plan and ‘Right to Light’ laws and precedents.


5. If you’re worried more generally about the future for Bristol’s development

You can copy and paste the below paragraphs and then write your own thoughts about this in your own words.

Bristol CIty Council has set out a number of policies to guide the development of the city’s Local Centres.

Policy DM8 is generally relevant as is DM9 which specifically states: “Throughout Bristol a network of 27 Local Centres serve the day-to-day needs of local areas. These centres are defined in the Core Strategy and identified on the Policies Map. Local Centres generally contain shops providing a range of groceries, fresh food and facilities such as post offices. They also often contain specialist or niche shops which contribute to the diversity and distinctiveness of centres, as well as including cafés, pubs or financial services uses. By ensuring an appropriate balance of uses is supported, this policy aims to maintain and strengthen the role of Local Centres in providing a community focus and in providing for day-to-day shopping needs.”

The Revised Local Plan consultation draft policy SSE2 notes: “Town centres will be the main focus for the development of main town centre uses outside Bristol city centre including uses that support the evening and night-time economy. Proposals for such uses in these areas will be supported, particularly where they would make positive use of vacant or under-used floorspace and diversify the centres existing retail and leisure offer.” 

Draft policy SSE23 focuses on the night time economy. Preserving the community and cinema space, augmented by flats, as the campaign group proposes would undoubtedly add to the value of Church Road’s local night time economy.

The Landrose proposal would deliver against these purported aims. It would also shift the balance and capacity of the area to a point where it would be almost impossible to meet them.