Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Employment Q35. What would help to attract more businesses to invest and grow here? [View all comments on this section]
Comment ID 10208161//1
Respondent Bristol Port Company [View all comments by this respondent]
Response Date 05 Dec 2018
Comment

This letter responds to the invitation by North Somerset Council (NSC) to comment upon their Local Plan 2036 - Issues and Options Document dated September 2018.

We acknowledge that the West of England authorities are working together to prepare a Joint Spatial Plan, and each are required to review and update their local plans alongside the emerging JSP. The Bristol Port Company (BPC) has generic and specific concerns relating to the JSP and these are known to the West of England Combined Authority. A copy of our letter dated 10 January 2018 and identifying our concerns is attached.

We respectfully remind you of BPC's role and the NPS for Ports before commenting on the Issues and Options  Document.

  1. Our role: statutory undertaker and nationally-significant commercial port

We are the statutory harbour authority and competent harbour authority for the Port of Bristol and own and operate the commercial port of Bristol (Port) which comprises the Avonmouth, Royal Edward and Royal Portbury Docks (RPD), falling within the districts of Bristol City Council and North Somerset.

The Port is recognised as a strategically important national asset, as  well  as having  significant local and regional importance. It is a multimodaltransport hub providing transit facilities for cargo with links by sea, road and rail to national and international destinations. We have consent under the Port of Bristol (Deep Sea Container Terminal) HarbourRevision Order 201O (SI 2010/2020)to construct a deep-sea container terminal on the foreshore of the existing Avonmouth Docks. This project will cater for the largestcontainer ships currently existing and will both secure and enhance the Port's ability to play its role as a key generator of economic growth for decades to come.

The Port currently has a key role in the supply chain for EDF's Hinkley C nuclear power station. Cargoes delivered by road, rail and sea are stored within the dock before they are required on site and then taken by vessel to West Somerset.

The Port links the Region and UK to the world with direct and feeder services for all freight needs and supports 9,000 jobs within the dock estate and almost 20,000 jobs across the UK.

  1. The National Policy Statement for Ports

The National Policy Statement for Ports 2012 (NPS) confirms that "the provision of sufficient sea port capacity will remain an essential element in ensuring sustainable growth in the UK economy" (paragraph 3.1.4) and concludes that there is a "compelling need for substantial additional port capacity over the next 20-30 years" (paragraph 3.4.16).

The NPS remains the most up to date statement of policy and has not changed with subsequent changes in Government. It summarises Government policy in the following terms:

  • encourage sustainable port development to cater for long-term forecast growth in volumes of imports and exports by sea with a competitive and efficient port industry capable of meeting the needs of importers and exporters cost effectively and in a timely manner, thus contributing to long-term economic growth and prosperity;
  • allow judgments about when and where new developments might be proposed to be made on the basis of commercial factors by the port industry or port developers operating within a free market environment; and
  • ensure all proposed developments satisfy the relevant legal, environmental and social constraints and objectives, including those in the relevant European Directives and corresponding national
  1. Issues and Options Document - Employment

The Port is an international gateway for the West of England Region (and beyond) and acknowledged as a strategic employment location.

The National Planning Policy Framework identifies economic growth as one of the overarching objectives to achieve sustainable development. We are pleased that the role of the Port is recognised in the Issues and Options Document with the associated need to accommodate growth but in developing the future Policies and Sustainability Appraisal, NSC must enable that development and expansion to take place beyond the Port's current boundaries.

In relation to future development at Portbury, we have consistently objected to the assessment by NSC of our development needs at RPD, which are immediate and compelling. Our requirement  for additional land today is acute and, put simply, at times of peak demand we have insufficient land to service the constantly increasing demands of our customers. We note that the  development of land for employment provides direct and indirect jobs and income for local authorities through business rates.

Since 2007, NSC has not made any further assessment of those development needs and, in particular, it has not reconsidered our needs following material changes to applicable policy, both under the NPS and also the National Planning Policy Framework (NPPF) (now July 2018). Paragraph 11 of the NPPF sets out a presumption in favour of sustainable development and requires plans positively to seek out opportunities to meet development needs.

Shipway Farm (as shown on the enclosed plan) was acquired by us for the purposes of our undertaking. It is the only currently viable site adjacent to RPD capable of contributing to our  future development needs and, to reflect the new policy requirements referred to above, it should be removed from the Green Belt and allocated for future port development.

A new Local Plan should, as a minimum, therefore include the following policy:

Land south-west of Royal Portbury Dock, at Shipway Farm, is identified as land allocated for uses associated with Royal Portbury Dock. Proposals for development of that area for port-related purposes will be permitted, subject to:

  • demonstrable need for that development that cannot reasonably be accommodated within the existing developed area at Royal Portbury Dock;
  • satisfactory environmental safeguards; and
  • there being no significant demonstrable harm to the amenities of residents of

The land to remain open and safeguarded against any permanent form of development until such time as the need for port-related purposes is demonstrated.

The land to be covered by the above policy should be that shown on the enclosed plan. Its allocation in the above terms would be congruent with the NPS, the NPPF and, of course, NSC's publicly stated key objective to maximise the role of the Port.

In addition to the above, decisions as to the inclusion of other areas as strategic locations for non­ employment development must not be made without taking into account the Port's needs in the same areas; this is especially pertinent to the challenges that Portishead may face in the plan period.

Summary
In relation to future development at Portbury, we have consistently objected to the assessment by NSC of our development needs at RPD, which are immediate and compelling. Our requirement for additional land today is acute and, put simply, at times of peak demand we have insufficient land to service the constantly increasing demands of our customers. We note that the development of land for employment provides direct and indirect jobs and income for local authorities through business rates.
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