North Somerset Local Plan 2018-2036: Pre-commencement Document

Comment ID 931233//1
Document Section North Somerset Local Plan 2018-2036: Pre-commencement Document Make a comment [View all comments on this section]
Respondent Deleted User [View all comments by this respondent]
Response Date 26 Jul 2016

CPRE North Somerset welcomes the opportunity to respond to this consultation but has concerns about the relationship between the West of England Joint Spatial Plan and the proposed North Somerset Local Plan.

The Pre-commencement document quotes ‘the Joint Spatial plan (JSP)……. will provide a new strategic planning context for North Somerset to 2036 in the form of a new district housing target and strategic locations’ despite as we understand it, the JSP not being statutory. If this is the case, then a non-statutory document will be imposing housing targets and locations on a statutory plan.

Paragraph 7 indicates the difficulties, it mentions the term "broad strategic distribution of housing and employment land/floor space, including strategic locations and key sites". How detailed will this be? Allocation of household and jobs to district level would satisfy the "strategic distribution" but how small can key sites be? Interaction between the Local Plan and the JSP will make the process much less efficient if key sites are too small. A distinction would need to be made between JSP key sites and district key sites, some of which will be smaller and not identified in the JSP. This illustrates the potential for confusion.

Given the decision by North Somerset not to accept a Metro Mayor, and the impact on the ‘devolution deal’, this must also impact on the relationship with the West of England Joint Spatial Plan and must generate the need for a review. North Somerset needs a period of stability in terms of Strategic Planning and not to be chasing a timetable of a new plan that meets the need of the JSP.

We are extremely concerned to note that recently adopted neighbourhood plans and others currently being undertaken may now be ‘out of date’ in relation to strategic plans. A Neighbourhood Plan was meant to provide a ‘bottom up’ and community ‘approach’ to local planning and it is not reasonable to make changes in such a short time period

In terms of the scope of the proposed Local Plan, we would wish to see included,
 Landscape
 Quality of land
 Food production (linking to the new food district)
 Lighting (new CPRE maps have been produced showing the status and impacts across the country including North Somerset)

We welcome the handling of minerals at a district level.
Waste collection and some waste disposal is appropriate at district level but there would be advantages to handling some waste disposal more widely and as infrastructure.

CPRE Avonside made a substantial response to the West of England JSP and Transport Study which expressed doubts about the projected housing targets and ambitious economic and employment ambitions driving those targets, rather than addressing current local need. Copies of these documents are attached for reference.

CPRE looks forward to a continuing dialogue in relation to the Local Plan for North Somerset and the wider area.