Site Allocations Plan March 2016

Document Section Site Allocations Plan March 2016 PUT FORWARD A SITE OR MAKE GENERAL COMMENTS Put forward a site [View all comments on this section]
Comment ID 11224833//3
Respondent Deleted User [View all comments by this respondent]
Agent IJP
Response Date 28 Apr 2016

3 The Green Belt surrounding Nailsea

3.1 The ability for Green Belt boundaries to be reviewed is set out at Paragraphs 83 and 84 of the NPPF. Clearly the need for such a review will need to be considered as part of the ongoing examination into the remitted policies. Until this process has been completed the SAP should not assume that the housing requirement can be met without amendments to the Green Belt. It is noted at page 2 of the SAP that the Core Strategy objective of continuing ‘to support North Somerset’s existing Green Belt’ has influenced the SAP. However, this approach will adversely restrict the scope of the document and may not reflect the outcome of the remitted policies examination later this year.

3.2 To understand the relevant evidence in relation to the Green Belt in North Somerset a review of the Joint Spatial Plan Green Belt Assessment has been undertaken by The Environmental Dimensions Partnership (EDP) on behalf of LVA and the findings are contained at Section 2 of the detailed Green Belt Review attached to these representations (Appendix 3).

The EDP report was initially prepared in relation to the emerging West of England Joint Spatial Plan consultation (November 2015) and the Green Belt Review that supported it. However, the issues identified by EDP in their report are also relevant to the SAP. It is understood that the Joint Spatial Plan Green Belt Review document is the most up to date evidence relied upon by North Somerset Council although it only provides an initial strategic assessment of the Green Belt across the West of England plan area. Paragraph 2.13 of the EDP report confirms that:

The Assessment provides only a very high level description of the cell and the extent to which it serves each of the purposes and there is no specific reference to it in the Conclusion section. The only reference to the function of each cell is they “directly serves two or more of the five purposes defined in the NPPF”.

Whilst these ‘tests’ are entirely representative of the purposes of the Green Belt as set out in the NPPF, this very simplified methodology and weighting system makes the Assessment less flexible and subtle when applied to smaller land parcels. It does not, for example, allow for a more detailed analysis of the extent to which the cells contribute to each of the purposes and what makes one cell any better or worse at serving each of the purposes. This is relevant particularly for making recommendations for re-drawing the boundaries – that is, the subsequent stage which is currently unavailable to inform the options consultation.

Whilst this simplification is in some way addressed through the consideration of all areas in the subsequent review provided in Appendix 1 of it, as stated above, the nature in which the cells were seemingly identified from a very large land area appears somewhat cursory.’

3.3 In support of proposals to develop land North of Nailsea, detailed cell analysis is provided in EDP’s report which applies additional criteria in line with a more detailed, site-specific study against the cells defined in the JSP Assessment. This supports the proposition that the Green Belt around Nailsea should be amended.

5.2 The north  Nailsea site represents the optimal location for an extension to the town. Indeed such an approach was supported through the emerging North Somerset Council Core Strategy process by Nailsea Town Council. However, this local aspiration was not carried through to the adopted Core Strategy as NSC did not consider that releasing land from the Green Belt was necessary in order to achieve the original housing requirement of 14,000 dwellings across the plan period. Since that time the housing requirement for North Somerset Council has increased to 20,985 following re-examination of remitted Policy CS13 and the JSP has also commenced. It is therefore logical that this matter should now be reconsidered.

5.3 The Town Council’s stance in relation to this matter has been previously confirmed in relation to representations submitted to NSC’s further consultation of the remaining remitted Core Strategy policies including Policy CS6 (Green Belt).