Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document North Somerset Issues Q5. 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 comments on this section]
Comment ID 20338913//7
Respondent Aston [View all comments by this respondent]
Response Date 11 Jan 2019
Comment

The Green Belt Report at Appendix A sets out the original purpose of the Green Belt.

It is agreed that the Green Belt has served a useful purpose but it is essential that in planning for the next 20 years at times of housing crisis in the UK that the review process starts with the consideration of all land use options. This approach is supported and promoted by the Landscape Institute in their 2017 policy briefing paper to Government.

The optimum outcomes will only be produced if the requirements for housing, employment, education, transport, recreation and all uses are considered against available supply and then each is tested for viability. A plan must be capable of delivering sustainable outcomes within the plan period, or the existing housing crisis will worsen.

There is no need to sweep away the Green Belt but the time has come for it to be reviewed in all forward plan making processes. Inevitably, sustainable development will in general be located around existing large service centres. The rigid enforcement of Green Belt is currently producing the counterintuitive proposal for new ‘garden villages’ to be established.

The locations selected for the proposed garden villages are in rural areas remote from the established settlements and large service centres. The initial case made in the West of England JSP for viability by BNP Paribas was not robust and left significant doubt over how infrastructure funding requirements would be met. That is not plan making with sustainable land use at its core.

(It is acknowledged that additional viability data has just been published in a consultation that overlaps with this NSC Local Plan consultation (WED005 12.11.18 until 7 January 2019) and a separate response will be made to that information.

In general terms we agree with the need to review the Green Belt for the purposes stated but the process described is unnecessarily narrow and it should also embrace the following:

  • All available land identified by the Local Planning Authority or submitted during the Call for Sites and other such processes should be reviewed and tested for all uses and not arbitrarily discounted if they are situated in Green Belt. For example, to discount all sites surrounding Portishead’s settlement boundary is illogical and does not comply with Government plan making guidance nor extant policy
  • The West of England JSP Strategic Green Belt evidence should be utilised as well as any other tested evidence submitted by land promoters, owners and
  • Detailed consideration must be given to the allocation of land in appropriate locations adjacent to settlement boundaries, outside of the immovable flood risk areas (which cannot be sustainable) where there are established larger settlement services and transport links already in existence or planned and funded. Such a solution could provide a number of non-strategic sites (under 500) that collectively remove the need for one or more garden villages.

(It is acknowledged that additional data to justify the SDL locations has just been published in a consultation that overlaps with this NSC Local Plan consultation (WED004 12.11.18 until 7 January 2019) and a separate response will be made to that information.

Key Issue, Point 2 – Yes villages, hamlets and smaller assemblies of houses within open countryside and washed over by Green Belt need balanced policies applied so that they can remain vibrant economic centres and are not blighted. There will be opportunities within these locations for development such as home offices, annexes for elderly relatives, Live-Work units to make use of fibre to the premises and generate local employment without the associated commuting.

Such opportunities may also arise within or adjacent to the settlement boundaries and here to there needs to be some flexibility to ensure rural vitality and prevent stagnation.

Open spaces within rural villages do need protection so that the character and feel of such rural locations is not lost but there must remain some flexibility. Each land parcel will have its own constraints and opportunities. Where a robust case is made for development and such development would help retain or enhance rural vitality, reduce commuting, or increase local employment opportunities then it should be considered on its merits.

Failure to deal with this effectively/flexibly will lead to areas stagnating and lacking the investment necessary to ensure long term vitality.

The Government have relaxed some of the General Permitted Development Order (GPDO) rules for re-use of redundant former agricultural buildings. That was welcome but a lack of flexibility on associated necessary building works creates perverse outcomes.

Former simple barns of steel frame and asbestos cement roofs become huge converted spaces of no external design character to ensure legal compliance under the prescriptive GPDO rules.

Planning needs good design and sustainable development. Far better to have a decision making process within policy which follows logic:

  • Has the building been in existence for 10 years or more?
  • Was its last use agricultural?
  • Is that use no longer required and if so why not?
  • Would it benefit from GPDO change of use rights?
  • Is the building is a sustainable location?
  • If the answer to each is ‘Yes’ provided design is agreed and the footprint and volume reflects the existing building then why not allow replacement to achieve the most sustainable long term solution and optimum use of land.

So in principle we agree that this is an important consideration but it needs to be even wider and innovative in its thinking. The Green Belt Report demonstrates the original intention and purpose which was to contain the merger of Bristol and Bath.

We support and agree with the Landscape Institute:

Green Belt policy, in its current format, fails to reflect the advances that have been made since the 1950s in a range of planning services. For example, the advent of digital technology, such as geographical information systems and remote satellite sensing, has given us the ability to examine, understand, analyse and plan for development in a way that was not possible when the concept of ‘Green Belt’ was introduced.“ (see here, page 2 point 3)

The West of England JSP Green Belt Review evidence also needs to be used not ignored.

All land use options should be considered from first principles to identify the best long term sustainable land uses and that will require a wholesale re-think of the application of the Green Belt. There is no need for large changes but we must remove the blight that it has created for rural settlements/hamlets/villages and establish whether small changes could avoid the need for garden villages and provide a more sustainable forward plan solution.

If the suggested controls/tests are made why not be flexible and enable replacement of redundant rural buildings over 10 years old with a new employment unit, live-work unit, or residential unit for a local person, something of a size/volume restricted to that of the original building (or less), but fit for the future, sustainable and of good (enhanced) design.

Summary
Need to review Green Belt - identify all available land and not arbitrarily discount because it is Green Belt, use JSP evidence as well as evidence submitted by landowners, consider allocations in appropriate locations adjacent to settlement boundaries outside flood areas. Opportunities may arise within or adjacent to settlement boundaries. Welcome relaxation of GPDO rules for former agricultural buildings - enable buildings over 10 years to be replaced by employment or residential for locals.
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