Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Submitted Sites Submitted sites [View all comments on this section]
Comment ID 21503137//4
Respondent James Millard [View all comments by this respondent]
Response Date 16 Jan 2019

 In support of our representations, we set out below evidence of such wider, non-strategic development opportunities which exist within the North Somerset area. In doing so, this demonstrates that with a sufficiently positive and robust strategic framework set out within the JSP, such wider opportunities for development can be realised. This will facilitate the delivery of a broad range of site options within North Somerset and the wider JSP area to provide choice, both in terms of location and product, but critically, providing greater flexibility in the supply over the Plan period, thereby reducing reliance upon SDLs.

Land to the east of Portbury

4.9 Land to the east of Portbury (Appendix 1) provides the opportunity to deliver a non-strategic site (c. 75-100 dwellings) that would benefit from and support existing services and facilities, including St Mary’s CoE Primary School associated with the settlement of Portbury.

4.10 This site is an edge of settlement site that benefits from good access to the strategic road network, with Junction 19 of the M5 Motorway accessed to the east via the A369 (Martcombe Road). The M5 borders the north of the site with existing residential development along Priory Road to the west. To the south runs the High Street, with playing fields and St Mary’s CoE Primary School located to the south west of the site. The site is therefore physically contained by hard infrastructure and built development on three sides, with playing fields and open fields extending eastwards and St Mary’s Church and Cemetery adjacent to the eastern boundary of the site.

4.11 An indicative masterplan has been prepared which demonstrates how this site can be delivered in a manner that provides for a logical and coherent edge of settlement development at a scale that is proportionate to the existing settlement of Portbury.

4.12 Development at this location will retain existing sports pitches, whilst providing additional amenity provision in terms of useable open space, alongside play areas and allotment provision. The indicative masterplan has been prepared to ensure that development proposals have due regard to the existing heritage assets, specifically the 12th Century St Mary’s Church and Cemetery.

4.13 The entire Portbury settlement is washed over by Green Belt, and consequently, the current adopted North Somerset Core Strategy makes no provision for growth at Portbury. However,through the JSP and North Somerset Local Plan 2036, set within the context of our representations presented above, this site provides a genuine opportunity to deliver a sustainable pattern of development that would support a spatial strategy which delivers a range of sites, both in terms of size and locations. The promotion of this site should also be considered in the context of NPPF paragraph 138 and the clear direction that when preparing plans, local authorities should consider areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt as well as locations beyond the outer Green Belt.

4.14 We set out below a summary of the five purposes of the Green Belt and the site’s contribution to it.

To check the unrestricted sprawl of large built-up areas

The development site provides a logical and coherent extension to Portbury that is not out of scale with the existing settlement. The development site is subject to significant urban influences which means that the site is enclosed and divorced from the countryside beyond. This includes the M5 Motorway to the north, the High Street to the South and the existing Portbury settlement to the east.

Limited contribution.

To prevent neighbouring towns merging into one another

Development to the east of Portbury will not reduce the separation of Portbury to other settlements. The site is physically contained by existing road infrastructure to the east such that there is no impact on neighbouring settlements.

Limited contribution.

To assist in safeguarding the countryside from encroachment

Given the physically constrained nature of the site, as result of the existing road network, the site does not result in any encroachment into the wider countryside.

Moderate contribution.

To preserve the setting and special character of historic towns

Portbury is not subject to any specific Conservation Area designations. As demonstrated in the indicative masterplan, the St Mary’s Church Listed building and its setting can be protected such that it does not result in harm to this asset.

Limited contribution.

To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

The site is promoted as a positive and deliverable sustainable development opportunity as part of a wider development strategy which includes, brownfield sites, large scale Greenfield Strategic Allocations and non-strategic sites.

Limited contribution.

4.15 For reasons set out above, the principal constraint associated with this site relates to its location within the Green Belt. This high level summary of the performance of the site in terms of its contribution to the purposes of the Green Belt demonstrates that this site could be developed without undermining the overall function of the Green Belt, specifically as it does not make a significant contribution to any of the five purposes as defined at paragraph 134 of the NPPF.

4.16 The JSP has an important function, in terms of providing the direction to North Somerset Local Plan 2036, and in this regard it should provide a clear direction that Green Belt locations should not be excluded from assessment to deliver non-strategic growth through North Somerset Local Plan.

4.17 In this regard we would welcome the opportunity to work closely with North Somerset Council, through the JSP and Local Plan process, to demonstrate how this site can provide a positive, deliverable and sustainable non-strategic site option.

4.18 The North Somerset SHLAA 2018 identifies the site, SHLAA reference HE18157, as being within Strategic Flood Risk Assessment (SFRA) fluvial flood zone 3b. The SFRA states that all areas in flood zone 3 should be considered as functional floodplain (3b) until an appropriate FRA demonstrates otherwise. The SHLAA Part 1 Assessment discounts sites entirely within flood zone 3b. However, the 2008 North Somerset SFRA Level 1 states that “If the SFRA indicates that a property or possible area for development is within or adjacent to a flood risk area, than a detailed Flood Risk Assessment (FRA) will be required to assess the site before any decisions can be made”. Nevertheless, the SHLAA Part 1 assessment immediately discounts sites stated to be within flood zone 3b, without further assessment.

4.19 It is considered that the 2018 SHLAA has incorrectly concluded that the site is located within Flood Zone 3. The Environment Agency Flood Map for Planning identifies the site as entirely being within flood zone 1.

4.20 The EA Map shows areas of flood zone 2 and flood zone 3 to the adjacent north west, but these do fall within the boundary of the site. To the north of the M5 motorway, the EA Flood Map shows large areas of Flood Zone 3, but that are benefiting from flood defences.

4.21 Duplicating the EA Flood Map, North Somerset’s Planning Map also identifies the entirety of the site as being within flood zone 1.

4.22 The Planning Map shows some small areas of Surface Water, to the north and north east corner, and towards the south of the site, indicating where surface water flooding could occur as a result of rainfall (at 1% chance of it happening in any year).

4.23 The 2018 SHLAA should therefore be updated to ensure that it is based on an accurate and reliable assessment as to the actual flood risk associated with this site.

Land adjacent to Long Ashton Road (A370)

4.24 This site comprises a triangular piece of land which is enclosed by Ashton Road (A370) along its southern boundary and the B3128 along its western, northern and eastern flanks. The site is located at the eastern edge of the North Somerset administrative boundary, adjacent to the boundary of Bristol City. The site provides opportunities for future development either as part of a large urban extension to the south-west of Bristol, or as an expansion of existing non-residential development, complimenting existing employment, retail and leisure land uses to the south of the A370. The Long Ashton Park & Ride facility is located to the south of the site, accessed via the B3128.

4.25 The recently completed South Bristol Link Road provides access from the A370 to the west of the site, through to Hengrove Park to the south of Bristol. This new Link Road also provides direct links to Bristol Airport.

4.26 The site is considered to be very well located to access the Metrobus Network, which is a cornerstone of the wider Bristol Transport Strategy. The network extends along the newly completed Link Road and the completion of the Ashton Vale to Temple Meads Metrobus Route will provide access from the Park and Ride direct into the centre of Bristol. In location terms, this site would be entirely consistent with the recognition within the submitted JSP that sustainability is closely related to proximity and accessibility to services and facilities, particularly in Bristol, Bath and Weston-Super-Mare(chapter 3).

4.27 The site is located within the designated Green Belt and as such has been excluded from consideration as part of a broad location of growth as a Strategic Development Location within the JSP. This should not, however, exclude the consideration of this site, through Green Belt release in North Somerset Local Plan, based on an objective assessment of its sustainability credentials balanced against its contribution to the purposes of the Green Belt.

4.28 The site provides a genuine development opportunity to deliver residential development as part of a wider urban extension to the south west of Bristol, or an employment-led development that compliments existing land uses in close proximity to the site.

4.29 In this regard we would welcome the opportunity to work closely with North Somerset Council, through the JSP and Local Plan process, to demonstrate how this site can provide a positive, deliverable and sustainable non-strategic site option.


Additional non-strategic sites required. Propose:
1) Land east of Portbury (75-100 dwellings) - indicative masterplan has been prepared and assessment undertaken in relation to Green Belt purposes.
2) Land adjacent to Long Ashton Road (A370) - very well located to access the metrobus network.