Core Strategy - Consultation Draft

Comment ID 3620513/CSCD/16
Document Section Core Strategy - Consultation Draft Chapter 1: Introduction Relationship to the Regional Spatial Strategy View all on this section
Respondent LandTrust Developments Ltd View all by this respondent
Agent Deleted User
Response Date 19 Apr 2010
Regional Spatial Strategy
2.1 We refer here to both RPG10 and to the emerging RSS10.
2.2 The Draft RSS was published in June 2006 and was the subject of an
Examination in Public during April to July 2007 with the Panel reporting to the Secretary of State in December 2007.
2.3 Draft RSS is a material consideration and one noted by the Secretary of State to be something which should be afforded 'considerable weight'. This is stated for the Secretary of State by the Deputy Regional Director of Regional Strategies, Housing and Planning at GOSW in a letter to Chief
Executives of all local authorities, dated 25 June 2009. The point is made in relation to planning applications, but is clearly equally true for the preparation of Development Plan Documents.
2.4 We think that the Council is misguided in its decision to ignore the Draft RSS. It is clear from the opening paragraphs of Chapter 5 of the
consultation document, and in the Minutes of the Council's Cabinet meeting
of 27 October 2010, that this is the basis of the current consultation. In
preparing the Core Strategy the Council has to start with what the position is now.
2.5 The LDF is required to be in 'general conformity' with the RSS. This is a statutory requirement from the Planning and Compulsory Purchase Act
2004, and PPS11 Regional Spatial Planning notes (para. 1.9) that an LDD
would not be in general conformity where an 'inconsistency or omission
......would cause significant harm to the implementation of an RSS'. The
emerging Core Strategy as currently presented in the consultation draft
would clearly fail this test.
2.6 The proposal for an urban extension to the south west of Bristol was
included in the Draft RSS with its principle, role, location and scale set out.
The proposal was not challenged by the Panel undertaking the Examination
in Public of the Draft RSS for the Secretary of State in July 2008, and whilst the wording of the relevant policy has evolved, the principle, role, location and scale were not changed by the Secretary of State's Proposed Changes.
The inclusion in the Draft RSS of an urban extension to south west of Bristol is not affected by the current work to address the need to ensure the Proposed Changes would withstand challenge couched in terms of the SEA
2.7 Confirmation that the need to undertake further work on the sustainability appraisal of the emerging RSS has no bearing on the inclusion in the emerging RSS of the proposal for an urban extension to the south west of Bristol is set out for the Secretary of State by the Deputy Regional Director of Regional Strategies, Housing and Planning at GOSW in letter to Chief Executives of all local authorities dated 25 September 2009.
2.8 RPG10 September 2001 is part of the statutory development plan. The
significant parts of the development plan for North Somerset in taking
forward the framework it establishes are in three parts:
- The overall spatial strategy that it establishes, and the respective roles of Bristol and Weston-super-Mare as Principal Urban Areas
- The strategic issues that arise from the current relationship between
Bristol and Weston-super-Mare and the way that this is addressed by
the RPG10 policy and is required to the be addressed by subsequent
Development Plan Documents at the local level
- The requirement on the West of England planning authorities to
undertake a review of the green belt.
2.9 The first two points are dealt with below, following consideration of the green belt issue.
2.10 Policy SS4 of RPG10 says that 'local authorities when preparing their
development plans should:
- Critically review the green belt to examine whether boundary
alterations are needed to allow for long term sustainable development
- Remove land from the green belt for development if on balance, this
would provide the most sustainable solution for accommodating future
development requirements'.
2.11 The Council needs to demonstrate that the required review has been carried out so that there is no threat to the soundness of the plan on the grounds of 'general conformity'.
2.12 This is not something that the Council can avoid. A review of the green belt is a requirement of the present development plan. Even if the Council believes there will be no RSS in future, it would then be for the LDF to address the strategic development requirement, and for the LDF to deal with both the general extent of the green belt and the definition of the boundary of the green belt.
2.13 We understand that the view GOSW has communicated to North Somerset
Council is that the Core Strategy should establish the boundary of the green belt in relation to allocated strategic development. We will make further representations on this point at the Submission stage of the Core Strategy, if it has not been dealt with in the meantime, with a specific map-based suggestion at that time as to how the green belt boundary could be established.
2.14 Fortunately there is no threat to the soundness of the Core Strategy on the point of general conformity with the RSS in respect of the green belt review, provided the Council is willing to be explicit about the demands made on it by the pursuit of proper planning. The Council is in a position to show that a of its senses:
- Of reflecting on the role of the green belt in this area in the light of
current circumstances, and;
- Of changing its extent and boundary as required by the 'exceptional
circumstances' that evidently exist.
2.15 This demonstration of having met the requirement of the regional
development plan would be through a combination of how provision is made
for housing and through the identification of the location of an urban
extension to the south west of Bristol.
2.16 The Council has the evidence to show that the proper consideration of
strategic development needs and supply leads to the need to change the
green belt to accommodate part of the development requirement. The south
west of Bristol is demonstrated to be the best location for strategic
development that meets the objectives for greater sustainability, with
particular regard to such as accessibility, the use of resources, and respect for environmental character and quality. Proper consideration of the purposes served by the green belt around Bristol and within North Somerset leads to the conclusion that an urban extension can be accommodated without eroding the contribution to those national policy purposes for which the Bristol-Bath green belt was created.
2.17 Evidence for this, as well as the wider point that this is the best location on the edge of Bristol for an urban extension, was submitted by Baker Associates during the preparation of the RSS and was part of the evidence base for the Draft RSS1. This report has been available to North Somerset throughout its development of its Core Strategy to date.
2.18 The Council has published (15 February 2010) its North Somerset Draft
Green Belt Assessment. This purports to compare relatively small parcels
of land to the south west of Bristol according to their contribution to green belt purposes - a task to which green belt policy is entirely unsuited - but seems to confuses many different factors in an evident attempt to arrive at a pre-determined output using supposedly objective criteria. As it is published as a consultation document we will make separate representations on the document, and if it is to be used to try to bolster the position the Council takes in its Core Strategy, we assume that those representations will be taken into account when this is done.
2.19 RPG10 as the existing statutory regional development plan establishes the current West of England spatial strategy, and in particular is clear on the relative role of Weston and Bristol. The plan reflects concern at the level of car-based work-related commuting from Weston to Bristol, with significant problems to the M5 and its junctions with severe congestion and the identification of an Air Quality Management Zone. The standing position of the Highways Agency as stated to both the EiP for the RSS and the Replacement North Somerset Local Plan public inquiry is that the strategic imbalance of homes in excess of jobs at Weston has to be tackled as a on the local authority working with developers and others established in Policy S10: Weston-super-Mare is to: 'limit further housing growth until employment development is more closely in balance with housing'. This basic strategic principle has been consistently carried forward in the emerging RSS from the beginning of its preparation, and the Council has agreed with and embraced this position through its contributions to the RSS.
With the Independent Inspector's backing the Council has taken the
principle forward in its Adopted Replacement North Somerset Local Plan,
with such as Policy E/1C for the Weston Regeneration Area, and statements
in the supporting such as that at para.7.35 which says: 'A key component of the early stages of the process is to ensure that the development that does occur is clearly 'employment-led'. This is in order to redress the imbalance that has occurred in recent years with housing development easily outstripping the creation of new w employment opportunities in the town.'
2.20 The practical consequence of this that has to be taken on board in planning and delivering development is to recognise that for the corridor between Weston and south west Bristol the number of jobs has to increase at the Weston end and the number of homes has to increase at the Bristol end in order to arrest and reverse the strategic inbalance that exists at present.
2.21 The Core Strategy consultation document may recognise this established implementation of this principle, but its spatial strategy only does half of the job and addresses only one half of the corridor. There is reference to the principle in the draft policies and text too, but the wording included is far too weak. In the event of it proving difficult to attract and nurture job-creating economic development at Weston-super-Mare, the way the plan would work in its present form would be to exacerbate the problem rather than address the strategic issue positively.