Local Plan 2036: Issues and Options Stage

Comment ID 20338913//6
Document Section 1. North Somerset Local Plan 2036: Issues and Options Document North Somerset Issues Q4. 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 on this section
Respondent Aston View all by this respondent
Response Date 11 Jan 2019

Key Issues Point 1-5 – agreed. Points to address through the Local Plan must also include provision of additional residential land use and Live-Work units.

Further development at Portishead (a larger town under Policy CS14: Distribution of new housing in the extant Core Strategy) coupled (where appropriate and relevant) with investment in necessary infrastructure and community facility upgrades is sensible rather than the establishment of garden villages. The key issues to address are:

  • The regeneration around the industrial docklands (east) is complete but there remains scope for release of land from GB to the south west at Black Rock, adjacent to the settlement boundary and within the largely level walk of the established service centre. This is historically the western industrial edge of Portishead (see Appendix A, Cultural and Heritage Report) and importantly lies outside of the flood risk constraint. It has already been urbanised with pavements and street lighting running the  full  length  of  the  site  frontage  connecting  it  to  the  centre  of  
  • The whole of Portishead is constrained by the historic Green Belt but the extant Core Strategy provides flexibility for appropriate additional development at the settlement boundaries (Policy CS31). This flexibility was introduced under examination by the Examining Inspector to make the plan sound (Inspectors Report, Policy MM04). We agree with the proposal to “Examine the potential for allocating additional employment land, possibly through small-scale Green Belt releases” but such localised Green Belt review must more widely include consideration of all future land use development options to accord with forward plan making
    • The detailed report in Appendix A sets out the history, purpose and amendments made to the Bristol & Bath Green Belt (GB) since its introduction. Through this forward plan process it is essential for the GB to be reviewed. Small scale changes such as implemented east of Keynsham, to release GB land for housing and thereby protect the UNESCO World Heritage City of Bath, illustrate the need and benefits of following central government plan making guidance (see Appendix A – Green Belt Report).
        • Flood remains a key constraint at Portishead and effective and appropriate land use allocations cannot be made until North Somerset Council’s outdated Strategic Flood Risk Assessments are updated to inform robust decision making. The United Nations Intergovernmental Panel on Climate Change (IPCC) October 2018 updated climate forecast has re-emphasises a crucial requirement in plan making. It is an essential requirement that forward plans avoid areas at risk of flood (whether defended or not) to ensure futureproof sustainable
        • No land should be allocated for housing development in areas at risk of flood as that cannot be sensible or   Sustainability  is  the  central  tenant  of  effective  plan  making.  There remain open questions over the maintenance and integrity of the existing flood defences at Portishead (See Appendix A - Flood Risk Report).
              • Transport and infrastructure investment is already underway to benefit Portishead including:
              • M5 Junction 19 roundabout and A369 (Portbury Hundred) to remove summer tailbacks (see here)
              • Metro West’s project to reopen the Portishead to Bristol branch line is due to be examined by the Planning Inspectorate in May/June 2019 and will upon consent be implemented to improve access between the two locations.
              • A cycleway/greenway is planned along the B3124 between Portishead and Bristol that will improve sustainable transport links.
          • Each of the above measures will improve the ability of this established larger settlement to accommodate much needed housing. The Replacement Local Plan should include a specific policy to encourage sustainable Live-Work units that can provide new flexible accommodation and local employment without increasing outward commuting pressures. Such space also removes associated commuting costs and can benefit from small business rates relief (non- residential element), assisting with the issue of affordability, encouraging local business start-up and supporting rural vitality.
        • Sites such as the land at Black Rock (Site reference HE18124) are within a sustainable location on the edge of a larger settlement, outside of the flood risk area and utility/service capacity has been verified with the relevant statutory undertakers. Such land could therefore swiftly bring forward beneficial housing including 35% compliant affordable and Live-Work units for local young people. There is far greater certainty of viability and delivery timing than a garden village scenario.
        • The Royal Portbury Dock has been expanding since its creation with additional parking/car storage land having been recently created close to the M5. The existing separation of this complex from the north eastern edge of Portishead is approximately 750m-1,000m. The primary purpose of the Bristol and West Green Belt was to separate and contain Bristol. If this gap is any further reduced or visually affected then Portishead will effectively be joined with the Portbury Dock and thereafter Avonmouth, Shirehampton and the outer Bristol urban areas. That would adversely impact primary Purpose 1 of the Green Belt. Great care must therefore be exercised in containing any further encroachment of Portishead to the south east towards Junction 19 or the Royal Portbury Dock west towards Portishead.
Further development at Portishead is sensible as opposed to garden villages. Scope for release of land from Green Belt at Black Rock. Need for localised Green Belt review. No land should be identified in flood risk areas. Transport and infrastructure is underway to benefit Portishead - J19 roundabout, rail, cycleway/greenway. Live-work units can reduce commuting. Important to retain Green Belt separation between Portishead and Royal Portbury Dock.