Adblock Bristol welcomes the opportunity to respond to the Local Plan consultation, given the importance of the policies set out in the document for our work to create a healthier, happier city to live in.
As part of this consultation, 1,800 people have signed a petition (online and on paper) calling for a policy of No New Billboards in the city. More details are given below.
Adblock Bristol is a Bristol-based campaign group active since April 2017 calling for a city that celebrates its creativity and independence, where communities have a say in what they see in the city’s streets and other public spaces. Adblock Bristol’s response to the latest consultation on Bristol’s Local Plan is set out below.
Failure to respond to concerns raised by local people in earlier rounds of consultation
The Local Authority has a statutory duty to consult the public and take into account their views during the plan-making process. During the first phase of consultation on the Bristol Local Plan review (February – April 2018) 24 respondents (out of a total of 436) raised concerns relating to advertising in the city, and calling for their concerns to be addressed in the next iteration of the plan.
The summary of consultation responses noted that 24 respondents to the consultation raised a concern about retained policy DM29 (Shopfronts, Signage and External Installations), where it was noted that – “policy required on outdoor advertising especially digital advertising/billboards to reflect changes in technology and impacts on privacy, wellbeing, the environment and disproportionate impact on deprived areas”.
The response provided was that ‘the National Planning Policy Framework sets out the policy approach for outdoor advertising’.
The summary of consultations also noted (p32) that:
“Several respondents raised concern with the level of advertising (billboards and digital) in the Lawrence Hill area in comparison to other areas of the city such as Clifton, and the harmful impact of this on residential amenity.”
While these comments were recognised in the summary of responses, there has been no adequate response to address these concerns in the latest draft Plan which is currently under consultation. Adblock Bristol finds insufficient the response that the National Planning Policy Framework sets out the policy for advertising, leaving Bristol City Council no room for crafting policies that allow them to act as good stewards of the public realm and for the health and wellbeing of both the local population and the environment.
We call the Council’s attention to the Mayor of London’s recent initiative, inspired by a similar policy in Amsterdam, to ban fast food advertising on public transport networks, following advice from public health bodies on the impact on childhood obesity. This move suggests that there is room for local and regional authorities to take a firmer stance on identified problems, despite nationally designated advertising regulations.
The strength of feeling against the weak existing policies on managing corporate outdoor advertising in the city is clearly building. Since the original consultation, Adblock Bristol has managed a petition that calls for the Council to introduce a presumption against new advertising sites in the new Local Plan, allowing for a default position of rejection of all new billboards, given the impact these adverts have for our mental health, levels of personal debt, our wellbeing and the environment. At the time of writing, 1,540 signatures have been collected plus 242 paper signatures which will be submitted to the Council by hand.
Adblock Bristol has made the point in the past that the current mechanism for local Bristolians to make their voice heard on the increasing impact of outdoor advertising in our public spaces is by objecting to individual applications for billboards. Over the last two years, residents across the city have mobilised over 800 planning objections to proposals to erect new billboards, or replace existing billboards with more intrusive digital billboards. While this has seen high rates of success, a number of appeals have been made against these decisions by the applicants, and it is becoming clear that this ‘firefighting’ strategy, on an application-by-application basis, is not sustainable and will struggle to keep up with the raft of applications being made across the city. Advertising firms can use their financial power and salaried staff to out-pace residents who volunteer their time to object to applications.
When residents have missed planning applications for new digital advertising screens, these applications are more likely to be approved by planning officers. This is evidenced by the Days Road application for a new digital screen in submitted in the summer holidays of 2018 (Planning Ref: 18/03884/A) which received no objections and was subsequently approved in September 2018. We understand that Bristol Council is supportive in combating inappropriate applications for outdoor adverts, however we again assert that this is an issue that requires dealing with at the plan-making stage.
Below we set out further comments on individual policies which we believe could provide a good ‘home’ within the existing plan for policies that help the public realm achieve the overarching goals of the plan. These policies are:
- Health and Wellbeing policies (particularly Policy HW3)
- Draft Policy DC3 (Local Character and Distinctiveness)
- Saved Policy DM9 (Local Centres)
COMMENTS ON INDIVIDUAL POLICIES
HEALTH AND WELLBEING POLICIES (PARTICULARLY POLICY HW3)
Paragraph 15.0.1 states that “the planning system has a role in supporting health, social and cultural wellbeing and creating healthy, inclusive communities. The policies in the local plan aim to deliver a safe and healthy city by addressing issues of air quality, pollution, water quality, contamination and the effects of land uses such as takeaways”.
It is encouraging to see the broad role of planning and land use management in securing health and wellbeing goals recognised within the plan. Adblock Bristol believes that it is in this section of the Plan that outdoor advertising can be best incorporated.
Policy HW3 (Takeaways) recognises that takeaway uses ‘have the potential to influence behaviour harmful to health or to the promotion of healthy lifestyles. Therefore, the policy takes those health considerations into account’ and the policy is designed to ‘limit children’s exposure to the influences on making poor food choices’ (para 15.2.2). Given this rationale, it seems contradictory to limit the number of takeaway outlets, without addressing the dominance of fast food advertising in promoting unhealthy lifestyles that are detrimental to wellbeing goals.
Companies known for pushing high fat, high salt and high sugar foods such as KFC, McDonalds and Coca-cola were in the top ten companies using outdoor advertising in the UK in 2017. (Source: Outsmart, Top 20 Out of Home Advertisers)
A 2017 report co-authored by Bristol Council described reducing childhood obesity as both a local and national priority, and notes that in Bristol over a third of Year 6 children were recorded as obese – above the national average. Several European cities have introduced bans on advertising sites within certain distances of schools, and (as discussed above) London has an initiative to follow in their footsteps. Impacts on obesity are one of a range of detrimental impacts corporate advertising can encourage within a city, however as a minimum interim measure AdBlock requests that similar regulations are discussed and developed for introduction into this Local Plan to combat the prevalence of junk food advertising.
Section 15.1.12 is about Air Quality
A policy against new billboards in the city would support the Council’s ambitions to reduce air pollution. Advertisers use billboards to sell new cars to car drivers. In 2017, the motor industry was the 7th largest buyer of outdoor advertising space in the UK (Source: Outsmart). Brands such as Ford, BMW, Mercedes, Toyota, Nissan, Audi, Fiat and Citroen spend around £25 million on out-of-home ads in the UK annually. This has the effect of re-enforcing the dominance of car culture and the social status symbol of car ownership at a time when the Council is trying to encourage a modal shift away from the car and towards active travel and public transport alternatives, as stated in the West of England Joint Transport Plan.“Use of mechanisms to reduce dependency on private car use in urban area, thereby improving air quality, public realm and supporting sustainable network improvements.” (Strategy for improving connectivity, West of England Joint Transport Plan)Some billboard companies, such as Maxx Media even boast that their targeted audience in Bristol will be stuck in stationary traffic jams: “Bristol is one of the most congested cities in the country with commuters spending on average a quarter of their journey at a complete standstill.”By comparison there are rarely, if ever, advertisements promoting sustainable travel (walking or cycling) or public transport.
DRAFT POLICY DC3 (LOCAL CHARACTER AND DISTINCTIVENESS)
There is a growing awareness that advertising hoardings not only affect our sense of wellbeing, but are also a visual burden for local character. Whether they are freestanding structures or spread across the wall of a building, outdoor advertising act as litter in the urban landscape.
The draft policy text requires that “development proposals which introduce new types of design, scale and form into its context will be appropriate provided that there is no harmful impact on local character”.
Adblock Bristol requests that specific wording is included in this policy that requires applicants to take account of how outdoor advertising affects local character.
SAVED POLICY DM9 (LOCAL CENTRES)
Saved Policy DM9 seeks to enhance the functions of local centres and their ability to meet day to day shopping needs, and to maintain a balance of uses in the centres. Bristol’s local high streets are vitally important for the life of the city and the independent traders the city is famous for are crucial in promoting the inclusive economic development the Plan seeks to secure (Draft Policy E1).
Materials that Adblock has put together highlight the impact of corporate advertising on local economic development. In particular, in 2017 the top 10 companies using outdoor advertising are multinationals including Coca-Cola, McDonalds, Tesco, Unilever and Diageo. It is recognised that corporate advertising hinders rather than helps the kind of local trader who brings vibrancy and resilience to Bristol’s high streets and local centres. Adblock Bristol requests that this support for local traders is reflected in the draft Plan.
We would like a presumption against all new planning applications for outdoor advertising sites included in the Plan.
We recognise the efforts that have been made to push back on individual applications for outdoor advertising, and the health and wellbeing goals that have been incorporated into the draft Local Plan. We also appreciate the significant financial pressures on the Council. However we request that the drafters of the Plan respond more robustly to the clear (and increasing) public pressure for reducing the impact of outdoor advertising on our city, which is threatening many of the very goals the Plan seeks to achieve. We call on Bristol to follow in the footsteps of other regional leaders placing health and wellbeing at the heart of their local policies and take bold action on this issue.
We look forward to seeing theses concerns, and those of our members, comprehensively discussed and reflected in the next iteration of the Plan.
24th May 2019