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 21503137//1
Respondent Newcombe Estates Company Limited [View all comments by this respondent]
Response Date 16 Jan 2019

Promoting land at Portbury and Long Ashton in the Green Belt.

Green Belt (Question 8)

3.1 Section 5 of the Issues and Options Consultation considers the Green Belt and notes that around 40% of North Somerset falls within the Green Belt designation. It is noted that the council attach great importance to the Green Belt and no strategic changes to accommodate large scale housing proposals are being put forward in this Plan”.

3.2 The importance and value of the Green Belt is understood, but the extent to which specific sites / locations contribute to the purposes of the Green Belt should be fully understood before a blanket restriction on Green Belt release is imposed.

3.3 It is evident that the overriding influence behind the JSP spatial distribution of planned development is the objective to “retain the overall function of the Green Belt”. However, this has not prevented the JSP from releasing significant areas from within the Green Belt, based on exceptional circumstances related to the need to accommodate proposed growth. Such an approach is not applied to North Somerset, where the established resistance to consider appropriate Green Belt release remains.

3.4 Page 15 of the Issues and Options document sets out the key issues related to Green Belt, but these are firmly set within the context of a general resistance Green Belt release. Potential solutions to these key issues are set out within the Issues and Options document and this includes the potential to consider Green Belt changes in locations identified as making only a limited contribution to the Green Belt purposes.

3.5 Such an approach would be supported and should, in our view, represent the starting point for the identification of sites/locations for development. The location of a site within the Green Belt should not automatically exclude a site from further assessment. It is critical that the site identification process does not conflate Green Belt with considerations of sustainability. The location of a site within the Green Belt does not render a site unsustainable.

3.6 A spatial strategy premised on the avoidance of the Green Belt may result is a strategy that would result in unsustainable patterns of development and could ultimately compromise the Plan’s objectives.

3.7 It is evident, and accepted within the JSP, that the release of Green Belt is a necessary requirement of the Spatial Strategy. It therefore follows that where a significant uplift of the JSP housing requirement is deemed necessary, this will require additional sites located within the Green Belt to be released to ensure the Spatial Strategy responds positively to wider opportunities for development. This not only applies to Strategic Development Locations, but will also necessitate the release of Green Belt sites to accommodate the Local Plan nonstrategic allowance, where it is the case that the JSP strategic requirement is increased.

3.8 It is noted that the North Somerset Strategic Housing Land Availability Assessment (SHLAA – 2018) confirms that the Part 1 assessment excludes those sites which are located entirely within the Green Belt. This is not based on any assessment as to the contribution such sites make to the purposes of the Green Belt.

3.9 For the North Somerset to advance a spatial distribution strategy which has the retention of the existing Green Belt as the key consideration is considered to be a flawed process. The identification of sustainable development opportunities should, in the first instance, be distinct from Green Belt considerations. It is a logical and coherent process to consider development options on a “policy-off” basis, before policy constraints are applied, in order to provide a comprehensive and transparent assessment of site options.

3.10 The exclusion of sites through the SHLAA Part 1 assessment based on their location within the Green Belt, fails to properly consider the extent to which such sites could deliver sustainable patterns of development. It imposes a blanket restriction on the consideration of such sites, and in doing so it pre-determines the overriding objective and spatial strategy of the North Somerset Local Plan, irrespective of the potential solutions presented within the Issues and Options consultation document.

3.11 The 2018 SHLAA states at para 3.11 that a site will be suitable “if it offers a suitable location for that use, is not subject to insurmountable constraints that cannot be mitigated, and would contribute to the creation of sustainable, mixed communities”. However, Part 1 of the SHLAA assessment comprises discounting all sites falling within the Green Belt, SSSI, Local Green Space, AONB, flood zone 3b, or greenfield sites with no boundaries adjoining an existing settlement boundary. Part 2 of the assessment then considers the remaining sites through a more detailed appraisal of their suitability, availability, and achievability, with each site categorised as either an existing housing allocation, a site that is ‘likely’ to have potential, one that is ‘less likely’ to have potential, or a site that is ‘unlikely’.

3.12 Land at Portbury is identified in the SHLAA, of site reference HE18157. This site is located within the Green Belt and therefore the assumption in the SHLAA is that this site is unsuitable as a matter of principle. This site has therefore been discounted through the Part 1 assessment. Of the 2,678ha of land across North Somerset considered in the SHLAA, just over 60% has been ruled out through the Part 1 assessment, without any of these sites being taken forward to more detailed appraisal.

3.13 Notwithstanding, the SHLAA acknowledges the difficulty in identifying sites to meet the dwelling requirement. The overall finding of the SHLAA is that “identifying sufficient suitable sites within North Somerset to meet the dwelling requirements emerging through the JSP is going to be extremely challenging and will require the consideration of a range of complex sites identified as having ‘less likely’ potential. Much of the dwelling provision is reliant on supporting infrastructure delivery”.

3.14 It is stated within the Issues and Options consultation document (page 19) that no specific sites for new development are proposed at this stage. However, given the deliberate strategy of excluding Green Belt sites and therefore not subjecting such sites to a comparable assessments as to their sustainability credentials, the premise for the future spatial distribution of non-strategic growth within North Somerset is already confirmed. The consequence of which is that potentially sustainable and deliverable sites, are excluded because they are located within the Green Belt, without any assessment as to how such sites/locations contribute to the purposes of the Green Belt as defined in the National Planning Policy Framework.


Extent to which sites contribute to Green Belt purposes must be fully understood before a blanket restriction is imposed. Follow JSP approach and release Green Belt - otherwise unsustainable development pattern. SHLAA is flawed as findings not based on Green Belt contribution. Identification of sustainable development opportunities should be distinct from Green Belt considerations. Land at Portbury identified.