Joint West of England Spatial Plan Issues and Options for Consultation
Consultation Response January 2016
Questions
1. Have the most appropriate critical spatial issues been identified in addressing housing and wellbeing; the economy; the environment; and transport?
BPT welcomes the recognition of the significance of the green belt and the appropriate recognition of the landscape and heritage value of the environment of the sub-region, in particular around the City of Bath World Heritage Site and the AONB.
We welcome recognition that the quality of new housing is at times of poor design.
2. Is the above vision the most appropriate one for guiding development and growth in the West of England up to 2036?
Yes.
Are there any changes you would like to see to the vision?
Add the words ‘and heritage’ after character (or refer specifically to historic and cultural richness in that sentence some other way).
3. Are the above spatial objectives the most appropriate ones for guiding development and growth in the West of England up to 2036?
Are there any changes or are there other objectives you would like to see?
We would prefer the environment spatial objectives to head the list as by doing this the special character of the sub-region will be maintained.
Housing para 2: include the word ‘human-scale’
Spatial objectives for the environment should specifically ensure the retention of the principle of the Bath/Bristol Green Belt and ensure that any loss of green belt is minimised.
Objective 8 include ‘and mitigate’ after ‘Respond to’.
4. Are we planning for the right number of homes? Is there anything else we should take into consideration regarding the number of homes?
We agree with the Inspector’s finding that the Bath HMA should be treated separately from the wider Bristol HMA, not least because the Bath HMA related to areas outside the JWESP (i.e. West Wiltshire). We would expect this to continue beyond 2019. We accept that the wider Bristol HMA will extend into B&NES UA.
BPT believes we need more homes in the right places, and more of them need to be affordable homes.
We think that SHMA/SHLAA need to consider the possibility of identifying increased numbers from windfall sites.
5. What needs to happen to ensure the homes we need are built by 2036?
All of the approaches identified in 3.11. In particular any specific market barriers to delivering homes of the type and number required (such as land value) should be examined to see whether any steps can be taken to improve this situation.
6. What needs to happen to ensure enough of the homes built are affordable?
We note the challenge inherent in delivering these according to the plan (para 3.8 onwards) and we think that it will be absolutely necessary to adopt the measures highlighted in para 3.11 in order to deliver the required number. Given this the strategy should aim to be more specific about how this is to be achieved.
Increased percentage contributions in planning policies.
Strengthening of planning policies to ensure that viability claims by developers do not diminish the contribution after planning.
A greater percentage of affordable homes within housing numbersNOT in addition to.
7. Have we identified the right employment issues?
No comment
8. Where should new employment land be located?
No comment
9. Is our priority of building more homes in Bristol and our main towns appropriate and how can this approach be achieved?
Yes. BPT agrees that the best place to provide development is within existing cities and towns on previously developed brownfield land. We will continue to resist pressure for an Urban Extension to Bath. However, we think that there may need to be reserved land within B&NES but outside Bath and its Green Belt.
We do not underestimate the infrastructure challenges and we also think that transport provision from ‘satellite’ towns need to be improved.
10. Have all the reasonable strategic locations been identified? Are there any others we should consider?
We welcome recognition in paragraph 5.12 of evidence that an urban extension to Bath would have an adverse impact on heritage and landscape assets and the exclusion of these options as possible locations.
11. Do you have comments on the suitability of any of the strategic locations?
Strategic locations in Keynsham and (in particular) Norton Radstock must be accompanied by transport infrastructure improvements and increase in capacity. Ideally a rail link between Norton Radstock and the main line would be reinstated.
12. In your opinion, do some strategic locations have advantages or disadvantages in terms of addressing the critical issues identified in Chapter 2?
No comment.
13. Which spatial scenario (or mix of scenarios) is likely to best deliver the plan’s objectives as set out on page 16?
Spatial scenario 1: Protection of Green Belt as it focuses on urban concentration. We recognise that the increased supply in non-green belt areas may require more effective investment in transport solutions for these towns and the active investment in methods of non-car and low-polluting car use.
14. If a new settlement is a solution, how big should it be and where would you suggest it could go?
We do not think a new settlement in the immediate vicinity of Bath would be appropriate. It is also hard to see where a new settlement could respond to the infrastructure and environmental constraints of the sub-region. We agree with the options paper analysis that such a solution is unlikely to fulfil the plan’s needs in the timescale.
15. What transport improvements or measures would be required to support the scenarios?
We would encourage forward-thinking transport solutions which reduce car use across the developed settlements and actively promote whole-area public transport use. We do not think new or expanded Park and Rides will displace car journeys and would encourage ‘link and ride’ solutions based in the developed settlements.
Provision of school/college transport solutions which are cost-effective for parents in all education sectors would significantly affect rush hour congestion in Bath.