Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document North Somerset Issues Q5. Do you agree with these or are there other challenges or issues which we have not included and how might the Local Plan address these? [View all comments on this section]
Comment ID 20338913//2
Respondent Aston [View all comments by this respondent]
Response Date 11 Jan 2019

This section of the consultation starts with a clear illustration of the challenges facing North Somerset by producing a map that illustrates the three major constraints washing over the majority of the authority’s area: The Bristol and Bath Green Belt, The Mendip Area of Outstanding Natural Beauty and Flood Risk from tidal and fluvial sources with much of the Gordano Valley and Somerset Levels lying at sea level.

The Housing and Land Availability Assessment reproduces a process chart from the National Planning Policy Practice Guidance (NPPG), identifying the key stages of the methodology recommended for the evaluation of sites for future development (page 6).

The NSC Housing and Land Availability Study (HLAA) starts off by using this process to sift all the potential sites identified as part of local plan consultations.

The study then factors in the potential housing land identified at the Strategic Development Locations (SDLs) within the publication version of the JSP which is currently undergoing examination.

The HLAA explains at page 10 how the process flow chart in the NPPG was then used for a part 1 assessment by considering all sites against a key list of constraints:

  • Sites designated Site of Special Scientific Interest (SSSI)
  • Sites entirely within the Green Belt
  • Sites entirely covered by Local Green Space
  • Sites entirely within the Area of Outstanding Natural Beauty (AONB)
  • Sites entirely within flood zone 3b
  • Sites with no boundary adjoining an existing settlement boundary (unless site is brownfield)

The process adopted by NSC has the immediate effect of disregarding all sites within Green Belt and the justification given is:

The submitted JSP has not identified a strategic requirement for the North Somerset Local Plan to release land in the Green Belt for housing development and the proposed SDLs are all located outside the Green Belt. The assumption in this study is therefore that new sites in the Green Belt are unsuitable as a matter of principle due to them being inappropriate development in the Green Belt. Clearly if the approach taken in the JSP were to change through the examination process, there are a range of Green Belt sites that could be considered subject to exceptional circumstances being demonstrated and progressed through the plan making process and in consultation with local communities” (para 3.13, page 13).

This methodology is unsound, will unnecessarily remove valuable sites in sustainable locations and fails to make use of evidence gathered within the JSP Stage 1 and Stage 2 Green Belt review.

The West of England JSP Green Belt Assessment Stage 2 (Nov 2016) makes it clear under Conclusions and Further Work (page 21) that the report was prepared as a strategic piece of work:

“3.43 Considering cells in combination, no substantial areas have been identified which make only a limited contribution to Green Belt purposes. There are no extensive tracts of land which, notwithstanding their current Green Belt status, have been shown to be unnecessary to keep permanently open by reason of their limited contribution to Green Belt purposes (para 3.43).”

It is the role of NS during preparation of a replacement Local Plan to:

  1. Examine, test and work up the detail for potential development sites identified within the West of England JSP of strategic consequence (>500 units) against the relevant
  2. To also look at non-strategic level for opportunities (<500 units) that may present themselves at local plan level to achieve much needed sustainable employment and housing development.

Good plan making requires a top down strategic focus and a bottom up local focus in assessing wide ranging sites against relevant criteria to achieve the best outcomes.

The Green Belt Stage 2 study should therefore be taken as the starting point of evidence for looking in greater detail and seeking to establish the optimum local land uses at non-strategic level. This may involve nip and tuck of the Green Belt where it can be demonstrated that the fundamental purposes of the GB will not be compromised.

Such an approach is highly likely to be able to provide more sustainable long term housing land solutions than the creation of the proposed new garden villages which will necessarily require significant new infrastructure and will create additional transport and traffic effects on rural highway networks.

Under ‘Further Work’ the GB study stage 2 states:

When determining future detailed Green belt boundaries the four authorities may wish to consider whether it is necessary to continue to include the cells making a limited overall contribution to Green Belt purposes” (para 3.46) and;

The four authorities may wish to consider using the approach set out in this assessment to assist in any detailed review of Green Belt boundaries which may be necessary in their Local Plans.” (para 3.47)

It does not suggest that any land affected by GB constraint should be ignored and not reviewed under the replacement plan process. To do so would be contrary to good planning practice.

Government Guidance for the completion of a Housing Land Availability Assessment (HLAA) study Published 6.03.14 by the Ministry of Housing Communities and Local Government sets out the following helpful information:

How should sites/broad locations be identified?

When carrying out a desk top review, plan makers should be proactive in identifying as wide a range as possible of sites and broad locations for development (including those existing sites that could be improved, intensified or changed). Sites, which have particular policy constraints, should be included in the assessment for the sake of comprehensiveness but these constraints must be set out clearly, including where they severely restrict development. An important part of the desktop review, however, is to test again the appropriateness of other previously defined constraints, rather than simply to accept them.

The process must start broadly and not be fettered by unnecessary rules. It must re-test potential land against previously defined constraints. There is evidence gathered within the JSP Stage 1 and Stage 2 Green Belt studies that should be used to evaluate sites.

In a number of cases, developers and land promoters will have undertaken detailed constraints work (ecological reports, landscape assessments, etc.). That information should be drawn into the forward plan process and any such evidence in support of promoted sites should be tested/objectively reviewed.

What types of sites and sources of data should be used?

A table of potential sources is provided and this includes: “Sites in rural locations, Sites in and adjoining villages or rural settlements and rural exception sites and Potential urban extensions and new free standing settlements.”

This does not mention screening in or out Green Belt sites but common-sense would suggest this should not be an arbitrary means for prematurely discounting sites from further evaluation. The objective should be to create the best possible forward plan that makes the optimum use of available land resources to produce the most sustainable development.

Key professional organisations including the Landscape Institute and Paul Cheshire, Professor Emeritus of Economic Geography, London School of Economics and Political Science recognise the need for Green Belts to be multi-functional to deliver social and environmental benefits. The Landscape Institute rightly concluded that the Green Belt requires ongoing re-evaluation to ensure its continued relevance (Green Belt Policy – April 2018). In particular they correctly highlight that since the 1950s, advances in digital technology including GiS mapping, lidar profiles, remote satellite sensing, etc. has given us the ability to analyse and plan development in a way that was not possible when the GB concept was first introduced. Plan making is the appropriate time to use such technology to revisit the GB.

The Royal Town Planning Institute (RTPI) led a debate among its members on the location for new housing and published a policy statement ‘Where should we build new homes’ in November 2016. They recognise the continued importance of the GB but acknowledge that development within existing built up areas will not meet all our needs and that after 60 years there is need for a wider debate “it is important to revisit the purposes that green belts need to fulfil over the coming generation.”

Wide ranging sources of data must be used during the evaluation of potential development land for example, any evidence submitted in support of sites by land promoters and developers and EIA screening and scoping opinions. The evidence submitted in support of land under the formal ‘Call for Sites’ should be tested and fed into this evaluation process and there is no indication that this has been done.

In the case of the Land at Black Rock (Site reference HE18124) detailed reports have been produced:

  • Planning Statement – Aston and Co
  • Bristol and Bath Green Belt Report – Aston and Co
  • Cultural & Heritage Report – Aston and Co
  • Landscape and Visual Impact Assessment – The Landmark Practice (1 of 2)
  • Response to NSC’s Evidence Base Landscape Sensitivity Assessment (2 of 2)
  • Ecological Constraints and Opportunities – The Landmark Practice (1 of 2)
  • Summary of Full Seasons Ecological Survey Work – The Landmark Practice (2 of 2)
  • EIA Screening Request and Response
  • Flood Risk Assessment – Aston and Co
  • Transport Note – Connect Highway Consultants

This detailed work has clearly defined the site constraints and opportunities and initial Architectural Design Layouts will now be developed.

These documents are supplied as separate pdf ‘Appendices’.

SHLAA process disregards all Green Belt sites. Methodology is unsound and will unnecessarily remove valuable sites in sustainable locations and fails to make use of JSP Green Belt review evidence. Opportunity for detailed Green Belt adjustment - likely to produce more sustainable solutions than garden villages. Use detailed constraints work prepared by developers. Detailed reports have been produced for Black Rock, Portishead site.