Sites and Policies Plan Consultation Draft

Document Section Sites and Policies Plan Consultation Draft Living within Environmental Limits DM13 [View all comments on this section]
Comment ID 1051265//2
Respondent Deleted User [View all comments by this respondent]
Response Date 18 Apr 2013
Current Status Accepted

Policy DM13: Development within the Green Belt

Following the publication of the Inspector's report into the Core Strategy examination in public (at which the Airport made representations) and before adoption of the Core Strategy by the Council, we wrote a letter to the Council dated 26 March 2012 (copy attached) in which we asserted that the Inspector's reasoning in his decision not to amend the Green Belt Boundary in relation to the Airport was incorrect.

The Council adopted the Core Strategy without the changes requested by us. Since adoption of the Core Strategy by the Council the following has occurred:

·        Policy CS6 is no longer an adopted policy following the legal challenge of the Core Strategy by Bristol University.

·        The National Planning Policy (NPPF) came fully into force in March 2013 after which development plans must be fully in accordance with the NPPF (see Annex 1 of the policy document).

·        The Town and Country Planning (Local Planning) (England) Regulations 2012 came into effect on 6 April 2012 which provide that previous local planning policies (e.g. the Core Strategy) must not conflict with relevant development plans (including the NPPF).

These changes are significant and our representations are based on our assertion that the Core Strategy (and particularly Policy CS6) is not sound and that the Green Belt policies relating to the Airport must be changed. Our specific representations with regard to Policy DM13 are as follows:

In preparing the Sites and Policies Plan, the NPPF now has primacy.  The Council therefore has an obligation to review its policy in respect of Bristol Airport and take steps to ensure that policy DM13 is in accordance with the NPPF.  I would refer you in particular to paragraph 85 of the NPPF which states that when defining (green belt) boundaries, local authorities should:

·        Not include land which is unnecessary to keep permanently open;

·        Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period; and

·        Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.

It is illogical and unworkable to require future airport development requiring planning permission within the boundary of the 2011 planning permission to demonstrate very special circumstances.  Planning applications should be determined on their merits in accordance with development plan policies.

We take this opportunity to restate the points made in our letter dated 26 March 2012 and request that the Council now makes the changes to Green Belt policy put forward previously by Bristol Airport.  Policy DM13 and the proposals map should be adjusted to remove the entire area within the redline boundary of the 2011 planning permission from the Green Belt. Without such changes we consider that the plan will not comply with the provisions of the NPPF and will not meet the tests relating to soundness.