Meeting documents
Cabinet
Wednesday, 11th January, 2006
APPENDIX 1
Council Executive 11th January 2006
Regional Spatial Strategy for the South West
Background Paper
1.0 Introduction
1.1 Members may recall that the 7th September Council Executive resolved to approve the West of England Joint Study Area First Detailed Proposals for a Sub-Regional Spatial Strategy for submission to the South West Regional Assembly (SWRA). It would be for the Assembly to consider whether the proposals should be incorporated in the Draft Regional Spatial Strategy (RSS) for the South West 2006-2026.
1.2 The Executive also referred the report to the 15th September Council for its views and recommendations to guide and inform future negotiations and discussions with the West of England Partnership and SWRA.
1.3 The 7th November Planning, Transportation, Economy and Sustainability Overview and Scrutiny Panel also considered progress of the RSS and its findings are set out in Annex 1.
1.4 An update report on the RSS has also been considered by Council at its 17th November meeting. This considered the First Draft RSS agreed at the Regional Assembly's meeting on the 21 October. Parts of the Second Draft RSS have only recently been made available to officers including the Sub Regional Statement and Policies for the West of England sub-region. Because of this a full analysis of the sections received has not been possible and as a priority this report focuses on the Second Draft Sub Regional Statement for the West of England. Detailed comments on the RSS policies contained in the First Draft RSS are set out in Annex 2. An update report may be necessary on the content of the emerging Second Draft RSS once this has been fully analysed.
2.0 Progress on the Regional Spatial Strategy
2.1 The First Draft RSS (RSS1) was published in October and its contents are under the following headings:
Section 1 - The Context of the RSS;
Section 2 - Information and Analysis which has helped shape the Strategy;
Section 3 - The Spatial Strategy;
Section 4 - Regional Approach to Transport
Section 5 - Sub Regional Statements and Policies
Section 6 - Harnessing Population Growth and Managing change
Section 7 - Enhancing Distinctive Environments and Cultural Life
Section 8 - Enhancing Economic Prosperity and Quality of Employment Opportunity
Section 9 - Addressing Deprivation and Disadvantage to reduce Intra Regional Inequalities
Section 10 - Ensuring People are treated fairly and can participate in society
2.2 The First Draft RSS (RSS1) can be viewed on the Regional Assembly website at
http://www.southwest-ra.gov.uk/swra/assemblymeetings/2005papers211005.shtml and copies are available in the Members Rooms.
2.3 Comments reported to the Council at the 17th November meeting are set out in Annex 2 together with additional comments on sections of RSS1 not covered in that report.
3.0 West of England Input into the RSS -The First Detailed Proposals
3.1 Members will recall that whilst the First Detailed Proposals submitted by the West of England Partnership to the Regional Assembly indicated the levels of development for the four Unitary Authorities they were not specific about location of development. The Regional Assembly have subsequently contacted officers seeking more detailed information including:
i. Confirmation of the housing distribution between the three main urban areas of Bristol, Bath and Weston-super-Mare as your First Detailed Proposals did not include specific quantities between 2011-2026.
ii. The contribution that housing development within the urban makes for each of the three urban areas listed above.
iii. Whether urban extensions are required to meet any shortfall in housing provision at the three urban areas.
iv. The scale and general location of urban extensions at each of the three urban areas.
v. Job growth levels at each of the three urban areas.
vi. Employment land requirements at each of the three urban areas.
vii. General location of new employment requirements (if beyond the existing urban area).
viii. How the emerging GBSTS conclusions are being taken into account.
ix. The conclusions of the WoE Green Belt review.
3.2 In relation to the last point the Assembly have commissioned their own study on a strategic review of the Green Belt including consideration of constraints mapping and sustainability assessment. This effectively is looking at possible locations for urban extensions.
3.3 The West of England Partnership at its meeting on the 16th December will be considering how it should respond to these requests given the now very short timescales involved. An update report on the outcomes of the Partnership meeting will be provided.
3.4 Officers of the Regional Assembly point out that the Regional Assembly's programme is to submit the RSS to the Secretary of State by the end of March 2006. To achieve this deadline, two Full Assembly meetings have been arranged for the 27th January and 10th March 2006. In addition, several Regional Spatial Planning and Transport Group (RSPTG) meetings are also programmed. In terms of signing off the RSS it is intended to present a revised version of the current emerging draft to the Full Assembly of the 27th January for discussion and if there is an inability to agree the document, or the need to make amendments, a final amended version can be discussed on the 10 March 2006.
3.5 To achieve this outcome, RSPTG on the 19th December is considering both the Joint Study Area (JSA) e.g. West of England JSA conclusions and District housing numbers. Another opportunity is available on the 12th January 2006 to discuss this further. Imminently after this meeting papers will be sent out in order to enable the Full Assembly meeting to take place. Therefore, the 'missing links' currently present in the emerging RSS, particularly the JSA elements, will have to be finalised by the 12th January 2006 at the latest.
3.6 In order to meet these deadlines the comments on the First Draft RSS in Annex 2 and those below on the Second Draft RSS are being brought to the attention of the Regional Assembly officers during December on the understanding that they are yet to be endorsed by the Council Executive.
4.0 Second Draft Regional Spatial Strategy (RSS2)
4.1 An early draft of Section 5 of RSS 2 sets out the following spatial strategy for the West of England and Bath & North East Somerset (see full text in Annex 3). At the time of writing a further draft has been received and I will provide an update report on the contents and issues it raises.
> Bath, a World Heritage Site, has an international reputation as a tourist destination, founded upon its architecture, public realm, retail `niche' market, cultural offer and surrounding high quality countryside. There is a need to diversify the local economy and accommodate housing, primarily through the continued development of brownfield sites, complemented by an assessment of the Green Belt objectives to assess the capacity to accommodate growth, without undermining the city's setting. Ambitious transport solutions will need to be considered to manage access to and within the city.
> Strategic locations to accommodate additional growth include:
Bath City Centre
Bath Western Riverside (regeneration area)
Bristol City Centre
South Bristol (including Hengrove Park)
Weston-super-Mare (Town centre and urban extensions)
Avonmouth, Severnside and Royal Portbury
Emerson's Green (including the Science Park)
North Bristol and south of the M4 Motorway
Urban extensions to the South West, South East and North East of Bristol
> In order to meet the needs of the existing and growing population, address issues of housing affordability, possible differences in job growth forecasts and help minimise long-distance commuting, provision should be made for at least 100,000 dwellings within the West of England over the period 2006-2026.
> Provision should be made for at least 70,750 dwellings at Bristol, at least 7,000 dwellings at Bath and up to 11,500 dwellings at Weston-super-Mare between 2006 and 2026.
> Outside of the above three urban areas but within the remainder of the administrative areas of the three Unitary Authorities, housing provision at the smaller settlements and rural areas between 2006 and 2026 should be at the following levels: Bath and North East Somerset about 3,500 dwellings; at North Somerset about 5,300 dwellings and at South Gloucestershire about 2,050 dwellings.
> Studies to date undertaken by the strategic planning authorities have identified the potential for at least 65,000 dwellings within the sub-region's existing urban areas by 2026. Whilst such a strong contribution from the urban areas is welcomed in the strategy, adding to its sustainability, the Regional Planning Body consider that increased densities and a more innovative approach, akin to the Mackay vision at Plymouth, could increase this urban contribution by at least 7,500 dwellings. Taking into account commuting patterns between Weston-super-Mare and Bristol, the additional increase in urban concentration should be primarily focused at Bristol, complemented by a Bath.
> Sustainable urban extensions to Bristol should be developed, immediately adjoining the south west (about 9,000 dwellings), south east (about 6,000 dwellings), north east (about 15,000 dwellings) and north of the Bristol urban area (about 6,000 dwellings) in conjunction with the provision of necessary infrastructure.
> A mixed development urban extension to the south of Bath of about 1,000 dwellings has identified to provide the range of housing and employment requirements that cannot be accommodated within the urban area. The precise location and composition of this urban extension should come forward through the LDD process, taking into account environmental and landscape constraints, World Heritage Site status, transport implications and incorporating the conclusions of the Green Belt review.
4.2 This strategy results in an increase in the proposed housing new housing provision in Bath & North east Somerset from 15,400 in the First Detailed Proposals to 16,500:
> Adjoining South East Bristol (Whitchurch to Hicks Gate) 6000
> Bath within the urban area 6000 with urban extension to the south of Bath 1000
> The rest of the District's towns and villages 3500
4.3 Initial analysis shows;
i. New figures result in a need to double the building rate within Bath excluding the urban extension.
ii. Current urban housing capacity study indicates Bath urban capacity as about 4,250 for 2006-2026. Bath Vision work may identify additional capacity.
iii. The build rate for the District's towns and villages is reduced from current levels of 219 per annum to 175 per annum
4.4 Main Issues are:
i. Can Bath deliver the urban capacity indicated given the previous build rates and historic environment constraints?
ii. Can an urban extension be delivered adjoining Bath given the constraints of the World Heritage site setting and former Fuller's earth mining south of Odd Down? What is the priority for the Council?
iii. Does the Whitchurch and South Bristol area have the capacity for 6000 dwellings and other uses?
iv. The RSS strategy does not allow for strategic levels of development at Norton-Radstock/Peasedown St John/Paulton area or Keynsham.
4.5 Taking account of these issues and the urgent need to influence the emerging RSS strategy, officers, following consultation with Group Leaders are recommending that the Council pursue the following strategy through the Partnership and Regional Assembly:
4.6 District Strategy
i. Bath and North East Somerset Council want to work with the South West Regional Assembly (SWRA) through the West of England Partnership (WoE) to achieve a realistic and deliverable policy framework upon which to build district policy;
ii. The Council needs the flexibility within the RSS to develop a bespoke deliverable growth strategy for Bath World Heritage site (the whole city) responding to the responsibilities of protecting the city's unique historic environment and setting. Working with the WoE, it proposes to integrate realistic growth at Bath with regeneration and sustainable growth at settlements to the south of the district to meet the City's economic and housing needs;
iii. The Council wishes to progress delivery of Bath's optimum capacity as a priority through putting Local Development Documents in place to enable realisation of the emerging "Vision for Bath" at the earliest opportunity;
iv. To work with Bristol City Council to deliver an integrated strategy to assist in the regeneration of South Bristol;
v. All growth must be accompanied with necessary infrastructure commitment.
4.7 Level of Growth 2006 - 2026
i. Bath & North East Somerset Council is prepared to negotiate with SWRA on increased level of growth (understood to be 1100) subject to this Council's requirements being met.
4.8 Strategy for Bath
i. Optimise capacity of Bath existing urban area to accommodate deliverable and sustainable growth respecting the responsibility to protect its world heritage value and enhance its economic base. (The council is developing The Vision for Bath) The realistic capacity within Bath is currently considered to be c 4000 (2006-2026);
ii. Subject to ongoing environmental impact studies, optimise the potential to implement a deliverable urban extension to the south of Bath which respects the responsibility to protect the setting of the World Heritage Site and the surrounding AONB and Green Belt. The considered maximum capacity is 1000 dwellings.
iii. Integrate the optimum deliverable capacity at Bath with sustainable growth at settlements outside of the Green Belt in the Radstock and Midsomer Norton area. The capacity could be about 4000 in this area, subject to provision of transportation and other infrastructure;
iv. To work with neighbouring Authorities to integrate growth strategies. It is too early to estimate any quantity at this stage.
4.9 Strategy Adjoining Bristol
1. To accommodate mixed-use urban extension to the south east of Bristol to assist in the regeneration of south Bristol and meeting Bristol's economic growth. Initial work indicates a capacity in Bath & North East Somerset of about 5000 dwellings.
4.10 Elsewhere in the District
i. To optimise the capacity of Keynsham (The council is developing a vision for Keynsham);
ii. To accommodate non strategic growth at other settlements within district ;
iii. Keynsham together with other parts of the district could contribute the remaining 1400 dwellings.
4.11 Because of the timescales this strategy with the endorsement of the Leaders is being taken to the meeting of the West of England Partnership on the 16th December 2005 (Workshop for the Joint Sub Group) to seek endorsement for it to be presented to the meeting of the Partnership with Regional Assembly Panel on the 19th December. This report therefore seeks agreement on the approach being pursued.
5. Conclusion
5.1 The Regional Assembly are aiming to complete work on the preparation of the Draft RSS by the mid January 2006. It is therefore essential that a response to the First and Second Drafts are forwarded to the Assembly during December. This report seeks endorsement of the detailed comments and an approach to a spatial strategy for Bath & North East Somerset.
ANNEX 1
Council Executive 11th January 2006
Regional Spatial Strategy for the South West
Background Paper
PTES Overview and Scrutiny Submission to the Executive on the Regional Spatial Strategy.
The Panel received a presentation and report from Keith Goodred on Monday 7th November. Below is a summary of the debate that took place.
Within this debate five key points were raised.
1. Review of the Green Belt
1.1 The First Detailed Proposals for a sub-regional spatial strategy for the West of England do not identify specific areas for new development at this stage. The report proposed general strategies, one of which was the use of smaller outlying towns to provide housing for people working in Bath. Transport and green infrastructure would also have to be integrated with this development. The Green Belt is very important for this area e.g. it is the setting for Bath itself. However, it can be reviewed.
1.2 30-40% of the new dwellings could be built without encroaching on the Green Belt (as per Paragraph 5.9 of the Report). However, 70% of the hectarage of Bath and North East Somerset is Green Belt, which the Regional Assembly needs to know. The Chair had queried whether or not at developing at approx. 100 dwelling per acres that the total loss of green belt could be up to 100 hectares, unfortunately it is still too soon to predict and that any review of the Green Belt should be preceded by a review of all other potential sites that could be realised. It was agreed that a more in depth study was required on the use of Brownfield sites and noted that Major Projects are currently looking at a vision for Norton Radstock, Keynsham and Bath.
1.3 Areas on the edge of the Green Belt (namely Timsbury, Radstock, Midsomer Norton) are under pressure for development. The Panel found it difficult to support this encroachment on these Green Belt areas. Areas such as Radstock, Midsomer Norton should become self-sufficient areas growing their own food supplies and not be turned into areas of housing and cars.
1.4 The proposed levels of growth are economically driven. Figures are forecasts and if aspects of that forecast change then the strategy will need to be reviewed and re-evaluated. The level of growth will impact on the need to review the Green Belt. The Spatial Strategy is a set of proposals and that strategy is based on the creation of 5000 new jobs.
2. Student Numbers Assumptions
2.1 The figures for the increase in housing do not include the student population. Student accommodation is an issue that needs to be addressed in the Local Plan. The Strategy has focussed around the creation of jobs to the area however the Panel are concerned that the increase in student numbers of possibly 600 per annum should be incorporated into these plans, and that the need for student accommodation should also be highlighted the current projected growth of dwellings does not take this into account.
3. Infrastructure
3.1 High growth requires a high degree of financial support for the infrastructure that is required to support this high growth. The West of England Partnership is working to gain this support through the Regional Assembly.
4. Affordable Housing
4.1 There is a great demand for affordable housing and the proposed development levels will increase the availability of affordable housing.
4.2 Of the 15,400 new dwellings, 30% should be affordable where this is on sites over a certain size or capacity. With respect to enforcing this 30%, the Council has planning policies to seek this on sites where the number of dwellings constructed is over a specified number or over a certain area. On sites where the developer is not constructing a large enough number of dwellings, the Council cannot enforce the 30% rule. This does mean that the overall percentage of affordable housing will be below 30%.of the 15,400.
4.3 The Regional Spatial Strategy is not a strategy developed internally. It is the strategy of the Regional Assembly. The issue of the Green Belt is an emotive one and we need to reassure the public that it will be protected.
4.4 As some parts of the Green Belt are more vulnerable than others we need to work with the Regional Assembly.
5. Communication
5.1 The Panel were concerned that the issue of communication between the Regional Assembly and Bath and North East Somerset Council is a sensitive one. The Regional Assembly requires the Council to give details of where the developments will be and then the Regional Assembly would give details of what infrastructure will be required. Whereas Bath and North East Somerset Council want to know the availability of budget for the infrastructure, and then decide where to place the developments.
ANNEX 2
Council Executive 11th January 2006
Regional Spatial Strategy for the South West
Background Paper
Comments on the First Draft Regional Spatial Strategy
1.5 The emerging Draft Regional Spatial Strategy includes strategic policies on spatial distribution and level of future development and regional approach to transport. It includes policies on the following:
> West of England Sub-Regional Spatial Strategy
> Transport (transport policies 1 - 15)
> Spatial distribution and levels of housing (policies A-E, H1 & H2)
> Delivering sustainable communities (SC1)
> Securing affordable housing (H3)
> Housing mix, size, type, tenure mix, density, use of previously developed land and buildings (H4 to 6)
> Flood risk (SC2)
> Sustainable construction (SC3)
> Development within environmental limits (SC4)
> Good design (SC5 & 6)
> Enhancing the diversity of our cultural life (C1&2)
> Protecting our distinctive environments (ENV1 to 6)
> Wiser use of natural resources (CE1 to 5, RES1 & 2)
> Minerals (MR1to 4)
> Waste Management (W1 to 6)
> The economy and sustainable development (E1 to 7)
> Addressing deprivation and disadvantage to reduce intra regional inequalities (ADD1)
Comments on the First Draft Regional Spatial Strategy reported to the 17th November Council
1.6 In Section 1 the RSS sets out guiding principles for a sustainable region and communities within it:
> Seek to reduce greenhouse gas emissions and better manage the future impacts of climate change on the environment, economy and society
> Minimise the need to travel through better alignment of jobs, homes and services
> Minimise the need to travel by car, by demand management, improved public transport, and effective planning of future development
> Use our natural resources wisely and aim to stabilise and then reduce our regional ecological footprint
> Build a strong, stable and sustainable economy realising the economic potential of the region
> Reduce economic disparities across the region providing prosperity and opportunities for all
> Protect and enhance the range of distinctive environments and cultural assets in the region and live within environmental limits
On delivery of these principles the Strategy is to:
> Meet the diverse needs of all people in existing and future communities through a clear vision and strategy based on the role and function of cities, towns and villages and their local character and distinctiveness
> Link the provision of homes, jobs and services based on role and function so that cities, towns and villages and groups of places have the potential to become more self contained and the need to travel is reduced
> Promote a step change in public transport and take steps to manage demand for travel and promote public transport `hubs'
> Encouraging business activity and particularly small businesses and their contribution to the region's prosperity
> Make adequate and affordable housing available for all residents
> Ensure that supporting infrastructure is delivered in step with development
> Promote sustainable construction as the norm in all future development
> Improve living and working environments, health and wellbeing by the provision of green infrastructure, better design and high quality development
> Increase participation in and provision of cultural activities across the region
> Ensure that access to opportunities is available to all residents including skills and training.
1.7 Section 3 sets out the Spatial Strategy for the region which is for significant change at a small number of strategically important cities and towns in order to support their economic role and smaller scale change elsewhere to achieve more balanced communities and a better local environment.
1.8 It sets out five core policies to guide development identifying the strategically significant cities and towns where most development will occur and criteria for development elsewhere.
1.9 For the north/central part of the region the emphasis is to realise the economic potential and service role of cities such as Bristol, Cheltenham, Exeter, Gloucester, Swindon and Taunton.
1.10 For Bath, Weston and some other towns development is to maintain and enhance their cultural, service and employment roles, balancing new housing and service provision with economic growth.
1.11 However, unlike the south east of the region (Bournemouth and Poole) no reference is made to growth in a way which recognises environmental limitations. This unfortunately seems to set the general tone of the whole RSS, appearing to place less emphasis on the need to recognise environmental quality and limitations in the West of England area. Bath & North East Somerset with the World Heritage site of Bath, two areas of Outstanding Natural Beauty, international and national wildlife sites, and generally high quality built and natural environment should be considered in this context.
1.12 Policy B of the Draft RSS refers to joint working between strategic and local authorities and stakeholders to enable identified places to be planned together through the relevant Local Development Documents (these replace the existing Local Plan system). Bristol/Bath and Bath/Trowbridge/Frome are identified. Further clarification is being sought on what this means as joint preparation of such policy documents will be complex.
1.13 Policy C on development outside `named' settlements and Policy E on development in the countryside also need further clarification on what constitutes meeting `local requirements' and what is considered to be a `small town'.
1.14 Section 5 of the Draft RSS sets out sub-regional statements and policies. The statement for the West of England is found in sub-section 5.1, pages 41-46 of the document.
1.15 Although much of the content of the submitted First Detailed Proposals has been taken into account in this latest version of the RSS, there are a number of major outstanding concerns, particularly in relation to:
> The overall level of growth proposed for this sub-region, which is higher than the forecasts on which the FDP are based (up to 7,500 additional dwellings for the sub-region).
> In particular, there is excessive reliance placed by the SWRA Secretariat, and also SWRDA, on high forecasts of job growth, which are not considered to be fully justified in this area.
> Statements in the RSS which imply that urban extensions will be developed in this area, requiring land to be removed from the Green Belt, rather than stating that further consideration should be given to possible extensions in the light of further work.
> The absence of positive references in the RSS to the possibility of future development outside (or not adjoining) the main urban areas, for instance adjoining smaller towns, which in this sub-region is an option worthy of further consideration on sustainability grounds. This would appear to militate against the possibility of urban extensions in the Norton-Radstock or Keynsham area.
1.16 A more detailed analysis of these key issues is set out in papers considered by the West of England Planning, Transport & Environment Group meeting of 14th October, agenda item 8 on the Regional Spatial Strategy and Regional Economic Strategy : Update and Key Issues, set out in Appendix 2 of that report. Electronic link is http://www.westofengland.org/downloads/5_rss.pdf
1.17 Section 4 of the draft RSS and sections 6-9 set out detailed policies on a range of issues including transport, housing, the environment, economy and deprivation. The analysis of these sections is still being undertaken by officers but there are some specific concerns already identified about policies and statements in Section 5 on the West of England Spatial Strategy and Section 7 `Enhancing distinctive Environments and Cultural Life' relating mainly to Bath's World Heritage site status. These concerns are:
5.1.1 Context
This section does not present an adequate assessment of the region's environmental assets (either built or natural) nor does it adequately present the character, strengths and role of Bath.
It should include:
> The exceptional quality of Bath & North East Somerset's environment (built and natural), the contribution this plays to quality of life, attractiveness of the area for investment and tourism as an essential industry for the region.
> Recognition of the contrasts between, and strengths of, the two major centres of Bath and Bristol and the importance of working with these particular strengths.
> Bath's international significance as a World Heritage Site.
> Stronger articulation of the importance of Bath & North East Somerset's natural environment - as a benefit not mainly as a constraint to development.
Additional wording is recommended to strengthen the 5th paragraph of section 5.1.1 - Context
93Bath is a city recognised by its World Heritage Site status as being of international significance for its historic environment. The quality and character of this environment, and the city's intimate relationship with the surrounding natural landscape means the key focus is on protecting and enhancing the environment while the City continues in its economic, social and cultural development. The environmental assets of the City and its environs have proved to be a significant draw to workers, businesses and visitors and are key to Bath's character, attractiveness and success.94
5.1.3 Strategy
The RSS does not reflect fully the key objectives of the spatial strategy set out in the FDP para 2.5 - particularly relating to brownfield development, protection and enhancement of key environmental assets, efficient use of resources and energy consumption. These should be added as without such key objectives the RSS reduces the importance of environment in the West of England.
5.1.4 Providing for the Economy
Needs to reflect:
> Recognition of Bath's contribution to the tourism draw for the sub-region and the need to invest in this to sustain it and work on diversifying it (as Jurassic Coast is recognised in Exeter area).
> Targeting economic growth in sectors that are environmentally sustainable in the context of protecting and enhancing the City's environment.
5.1.6 Development distribution
Stated overall priority `to maintain and improve attractiveness of urban areas as places in which people wish to live, work, visit and invest' misses the environmental significance aspect and is weakly worded.
Like the previous section, this part should acknowledge the sensitivity of Bath to increased levels of development.
5.1.8 Transport
Should recognise the need to have traffic and transport solutions for Bath that meet the needs of the City and support the needs of the sub-region and region, but also support the needs of the environment and are not detrimental in their impact.
5.1.9 Other infrastructure
Need recognition that Bath has a huge challenge with its public realm and that this is a key factor in sustaining the City both as a good place to live and invest in as a business centre, as a World Heritage Site and as a successful tourist and visitor attraction (see Gloucester/ Cheltenham section).
Bath should be a priority for investment in environmental enhancement - particularly historic fabric and appropriate quality public spaces and infrastructure.
Section 7 Enhancing distinctive environments and cultural life
7.1 Enhancing Cultural Life
Bath should be mentioned as a major cultural venue in the region.
7.2 Protecting and enhancing our distinctive environments
Throughout this section the accompanying text is almost always stronger than the wording of the policies. This is a weakness that should be addressed as it is the policies that will be applied and quoted.
7.2.1 Policy ENV1
To have the first policy about environmental conservation and enhancement focus on what should be done to assess and mitigate the impact of development on those assets gives the wrong message. There should be a general policy that conserves and enhances those assets.
While the approach of Policy ENV1 is appropriate for dealing with development affecting environmental assets, it does assume that development will be taking place. Conservation and enhancement work will also take place without always being driven by development.
Need stronger recognition of the international significance of World Heritage Site status in the supporting text.
The supporting text states that the environmental policies will help deliver the Regional Economic Strategy `where the region's unique environmental and cultural assets are protected and enhanced so that they will continue to attract investment and develop economic linkage' - but the environmental policies do not fully reflect this aim.
Concern at the statement in the text `Historic assets are also under pressure 85 we need to find ways of harnessing these changes to protect and enhance our environmental assets'. Environmental protection and enhancement should be carried out for its own sake, and not only through development. Also, this should be turned around to state that necessary growth and change should take place in recognition of environmental assets and without degrading them.
7.2.4 Historic Environment
This section is weak in introduction and does not do justice to the assets of the region. It also appears to downplay international status.
To state `future growth will put pressure on historic assets' and then `there are also opportunities to use the historic environment to enhance new development' is of great concern. New development should complement and strengthen the historic environment. The existing historic environment will not lift the quality of an inappropriate development or mitigate its impact. Loss of wetlands is a nature conservation or landscape issue. The list of pressures is inadequate to accurately describe the current pressures. It should highlight development pressures on urban historic environments.
Policy ENV6
The difference in strength between Policy ENV6 and those for landscape, nature conservation and coast is noticeable. It is much weaker, saying only that local authorities `should seek to conserve and enhance the historic environment' whereas other policies incorporate phrases such as `will be sustained and enhanced'.
In particular the policies for AONBs and National Parks, and for Coastal areas, are given higher levels of protection - which considering Bath's international status as a World Heritage Site, is unacceptable. Development in coastal areas `must ensure the conservation of the coastal environment for its own sake and as an environmental, economic and quality of life asset'. The conservation and enhancement of AONBs and National Parks `will be given priority over other considerations in the determination of development proposals'. This level of protection is important for the historic environment such as Bath and is completely justifiable considering its international status.
This policy is also very development led. It misses out conservation and enhancement for its own sake - mitigating the effects of development should come after this.
The accompanying text contains a much stronger phrase than is in the policy itself. It states the three World Heritage Sites `must' be protected from harmful development. Having this in the text and not the policy is inconsistent.
Additional Comments on the First Draft Regional Spatial Strategy not reported to the 17th November Council
Section 3 - The Spatial Strategy
Para 3.2 - Reference to Bath not strong enough re environmental constraints.
Policy A - Does not recognise any environmental limitations in Northern sub-region e.g. Bath. In South East of Region it does recognise limitations.
Policy B - Joint working for Bristol/Bath and Bath/Trowbridge/Frome - what mechanisms are envisaged?
Section 4 - Regional Approach to Transport
TO FOLLOW
Section 6 - Harnessing Population Growth and Managing Change
Policy SC1 - Delivering Sustainable Communities through sustainable construction
Clause (i) unclear what is meant by `forms of development'
Clause (iv) `cultural' facilities needs defining
Policy H2 - Phasing of housing development and ensuring land supply
Requirement for joint action plan for each Housing Market Area - Is this a reference to a Local Development Document or other non-statutory document. If the former this will be difficult to co-ordinate as it includes the other UAs in the West of England and adjoining districts.
Under or over -provision of housing may be due to a range of factors e.g. economic performance, market factors or other reasons. It may be necessary to review first rather than compensate.
Policy H3 - Securing Affordable Housing
First para - Affordable housing 6,000-10,000 per annum. Requirement for breakdown between social rent, intermediate and below full cost by settlement would be too onerous and inflexible. It will depend various issues e.g. local need at the time of planning application, viability etc and is best negotiated on a site by site basis.
3rd para - policy too onerous and prescriptive on processes and consultation.
Para 6.7.3 - Affordable housing outside named settlements. Strategy may lead to further problems of delivery of affordable housing in rural areas and smaller towns. Some local flexibility in allocation of sites in areas of high need may help.
SC3 - Building to sustainable construction standards - mainly outside of planning control.
SC4 - Development within environmental limits - phrases such as `one planet' need to be defined. Also needs to explain what is South West Regional Checklist for Sustainable Developments?
SC6 - Design of new housing - Some of these items not deliverable under current planning legislation e.g. internal design requirements, construction standards.
General - Reference to co-ordination for LDD housing policy across market housing areas and associated consultation will be time consiuming and may slow down LDD preparation process.
Section 7 - Enhancing Distinctive Environments and Cultural Life
7.1, second para - Should have reference to Bath WHS.
3rd para - Reference to `local plans' should be amended.
Policy C2 Promoting local cultural provision - Should refer to provision of accessible cultural facilities as referred to in text.
ENV2 Landscape - Not clear what is meant by undertaking landscape assessments at the strategic level. Again promotes partnership working without looking at impact on speed of process or costs.
ENV3 National Parks and AONBs - Supporting text. The Spatial Strategy in section 3 does not appear to take account of AONB constraints in West of England or World Heritage Site status.
C4 - Planning for Coastal Change - Clause (iii) - Grammatical problem relating to last part of sentence which loses meaning.
3rd bullet - It will be for LPA to decide whether to produce SPD as it has resource implications and there will be other priorities.
5th bullet - How can LPA include water conservation measures in new development. This is for the developer. Wording needs amendment.
MR1 - Minerals Provision, bullet point 2 - Also need to take account of locally important designations.
W4 - Provision of facilities for the disposal of hazardous waste - No reference in last section to concerns for human health, which should be included, and also environmental impacts.
Section 8 - Enhancing Economic Prosperity and Quality of Employment Opportunity
First para - No reference to environment at all - see bottom of page 102 quote from RES.
Measurable outcomes - page 133 - within 3 years each LA will have undertaken a comprehensive employment land review which recognise functional relationships with labour markets beyond LA boundaries - how will this be done and resourced?
8.2.3 first para - assume this is referring to the agricultural industry.
8.2.3, third para - changes to land based industries should take account of nature conservation, archaeology and historic environment as well as impact on the landscape.
Policy E1 - Successful and Competitive Businesses 3rd and 4th bullet points - facilitating the spatial links between skills development, business productivity, prosperity and sustainable communities needs further explanation. The same concern of lack of explanation applies to the clause on promoting innovation.
8.3, 6th para - Doesn't deal adequately with protecting existing stock but emphasises mixed-use proposals for sites. Whilst this can be successful care must be taken that mixed use developments do not result in little or no gain in meeting employment objectives. Experience shows that it can be difficult to achieve delivery of the employment uses with the site then coming under further pressure for more housing. This in turn may result in the need for greenfield development for new employment uses. The RSS should set out clearly how this issue can be addressed.
Policy E2 - Employment Land Provision - the implications (e.g. for urban housing capacity and Vision for Bath) of ensuring a range of sites to meet economic needs are made available need to be noted, particularly in Bath where significant economic growth is assumed.
Policy E3 - Review of employment sites - Requires 5 year supply of sites.
Last clause - Unclear what is meant by poorly performing sites. Poorly performing sites in sustainable locations may be needed in the longer term as shown by employment land studies. Approach put forward may well result in greenfield pressures at a later stage.
Policy E4, Town centre and retail strategy second bullet point - Appears to be a conflict. If some centres are to retain sub-regional role (first sub bullet point) then they will need to maintain growth and investment in line with that sub-regional growth, not just local population and household expenditure growth. If not then they will not have capacity to meet sub-regional demands.
Policy E4 - given the potentially high level of housing in Bath there will be significant implications for Bath city centre (in terms of retail/leisure growth) of the policy of maintaining growth and investment in step with planned population/expenditure growth. Again links with Bath Vision need to be made. Would a caveat in the policy be useful e.g. subject to supply of suitable sites, demands from other uses for land, resolution of constraints etc?
Policy E4 - Fourth bullet point - Include petrol filling stations and other services.
Bath is listed as one of three main retail centres in the Region (what about other centres e.g. Exeter, Plymouth, Bournemouth?). Whilst the Council should welcome this it needs to be aware of the impacts associated with growth.
The text suggests that it is proposed to introduce a table setting out retail floorspace growth in the major centres. Whilst there may be a need for regional co-ordination of such growth inclusion of the table suggested is not supported. The scale of growth should be left to individual authorities to determine (within a regional/sub-regional framework) as assessments of future expenditure growth and floorspace need are highly susceptible to the assumptions made. These assumptions will be particular to the centre in question and can not necessarily be standardised. The RSS however should refer to assessments of floorspace need/growth for the major centres being co-ordinated to ensure that planned growth in other centres is taken into account.
Second para of supporting text - See comments above under E4.
Policy E6 - Tourism - makes no mention of impacts on environment, including landscape, nature conservation, historic environment. It is critical as these quality environments are what attracts tourists in the first place.
Section 9 - Addressing Deprivation and Disadvantage to reduce Inter Regional Inequalities
Section 10 - Ensuring people are treated fairly and can participate in society
2nd para - The RA have not ensured an active, inclusive and creative approach to consultation on policy and delivery. It is failing to properly consult on the First Draft RSS in any meaningful way with the wider public.
10.4.1 - Gypsies & Travellers - It is not possible to complete needs survey to meet FDP timescale.
ANNEX 3
Council Executive 11th January 2006
Regional Spatial Strategy for the South West
Background Paper
Second Draft Regional Spatial Strategy -
Section 5: Sub Regional Statements and Policies
Section 5
NB: The following sections include transport and other infrastructure requirements for each area. At this stage these proposals have not been prioritised. This will happen in tandem with the Regional Funding Allocation process for submission in early 206.
The North and Centre of the Region
5.1 West of England Spatial Strategy
5.1.1 Context
i. Bristol, the largest urban area in the south west, is at the hub of the northern part of the region and is a national `Core City', one of only eight in England. Its role is not only critical to the future success of the region, but also to the success of the national economy, as reflected in "The Way Ahead - Delivering Sustainable Communities in the South West".
ii. The West of England encompasses the Bristol urban area, Bath, Weston-super-Mare, and surrounding areas. It contains over 20% of the South West's population and economic activity, with over two-thirds of its jobs being within the Bristol urban area. The sub-region's economy supports levels of prosperity and growth above both regional and national averages. Its influence extends across much of the region. It acts as a functional city-region, with over 90% of jobs in the West of England filled by residents of the area. However, commuting across its boundaries has intensified between censuses, particularly through increased use of the motorway network.
iii. The Bristol urban area adjoins the M4 and M5 motorways and is located on the London to South Wales main line railway. These strategic networks, together with Bristol International Airport (providing flights connecting the area and region to global destinations) and seaport, provide good connectivity to other areas, but continuing growth will place increased pressure on them, and this will require positive management and investment in both strategic and local transport systems.
iv. The area also has the largest concentration of jobs in the region, particularly in the knowledge based and creative industries, showing strong economic growth in the recent years. Much of this job growth has occurred north of Bristol in South Gloucestershire, close to the motorways. In contrast, the south of the City has attracted less new development and investment. This imbalance has contributed to unemployment and deprivation in south Bristol and concerns about rising congestion and over-development on the north of the City.
v. Bath, a World Heritage Site, has an international reputation as a tourist destination, founded upon its architecture, public realm, retail `niche' market, cultural offer and surrounding high quality countryside. There is a need to diversify the local economy and accommodate housing, primarily through the continued development of brownfield sites, complemented by an assessment of the Green Belt objectives to assess the capacity to accommodate growth, without undermining the city's setting. Ambitious transport solutions will need to be considered to manage access to and within the city.
vi. Weston-super-Mare has undergone major changes through housing development, the loss of industries and restructuring in the tourism industry, developing more of a dormitory relationship with Bristol which current and future policy needs to address. Smaller towns in the sub-region also contain significant levels of employment and local services which meet many of the needs of their residents, although many residents work in Bristol or Bath.
vii. The Severn Estuary, two Areas of Outstanding Natural Beauty and the wider countryside are valuable assets which enhance residents' quality of life. Together with the Green Belt which covers most of the area's countryside, these present challenges in realising the area's future growth requirements, particularly in enabling the continued success of the Port of Bristol and Bristol International Airport, whilst also providing sufficient space to accommodate the number of homes required to meet the needs of a buoyant economy.
5.1.2 Vision
i. A vision for the sub-region has been developed by the West of England Partnership, which draws together leaders of the four strategic authorities with social, economic and environmental partners. Their vision's main theme is that the area will be `One of Europe's fastest growing and most prosperous sub regions which has closed the gap between disadvantaged and other communities - driven by major developments in employment and government backed infrastructure improvements in south Bristol and North Somerset'. Key aspects of the vision include:
· a buoyant economy competing internationally;
· a rising quality of life for all through healthier lifestyles, better healthcare, greater affordable housing and the development of sustainable communities;
· transport solutions which link employment opportunities and local services, control and reduce congestion, and improve strategic connections (including to areas outside the region) by road, rail and through Bristol International Airport and seaport;
· cultural attractions that are the envy of competitor city regions across Europe drawing in talented, creative workers and affluent visitors;
· sustainable mechanisms to deliver the vision including energy efficiency, protection of air quality, minimisation and management of waste, and the protection and enhancement of the natural and built environment;
· benefit from the areas distinctive mix of urban and rural areas;
· leadership to influence regional and national government and deliver change.
5.1.3 Strategy for the West of England
i. The Strategy for the West of England, to benefit the sub region, regional and national economies, maintaining and improving the quality of life of residents, is centred on:
· promoting urban renaissance, especially in Bristol, Bath and Weston-super-Mare, making them better places in which to live, work, visit and invest, particularly through making the best use of previously developed land;
· regenerating areas of disadvantage, particularly in Bristol and Weston-super-Mare;
· promoting and enhancing prospects for sustainable development and investment in south Bristol and Weston-super-Mare;
· ensuring that the Green Belt continues to perform its fundamental strategic roles and objectives in the area, while strategically reviewing its general extent to meet the sub-region's requirements to accommodate sustainable patterns of development;
· overcoming existing deficits in physical and social infrastructure in the West of England, providing infrastructure to create balanced new communities as part of the sub-region's successful economic expansion;
· delivering a step change in the quality of public transport and traffic management within the Bristol urban area, Bath and Weston-super-Mare, and between the cities, smaller towns and rural areas across the sub-region;
· encouraging the provision of green infrastructure throughout the sub-region, maximising the potential of the Forest of Avon, and measures to enable the Green Belt and rural areas to play a positive role in contributing towards a high quality of life for all residents in the sub-region.
5.1.4 Providing for the Economy
i. For the West of England as a whole, the future relationship between the location of economic activity and jobs, the quantity of jobs and the places where those people occupying the jobs live is one of the main issues to be resolved by positive planning in the RSS. Resolving this issue will not only provide a better balance between jobs and homes, but also create greater opportunities for journeys to work by public transport, walking and cycling, a key objective for the wider area.
ii. The West of England, particularly the Bristol urban area, has the largest concentration of jobs in the region overall, as well as the greatest number employed in the knowledge based and creative industry sectors. This is a very significant strength for the future. In addition, the area has shown strong growth in jobs in the recent past. Throughout the 1990's and into the present century job growth in the West of England, particularly the Bristol urban area has been on a rising trend. Economic growth has outstripped previous estimates made during the formulation of RPG10 and the existing Structure Plan. In order to proactively plan to deliver a more sustainable society and maximise the areas economic potential, it is important that future levels of job growth are not underestimated. Taking into account economic forecasts and recent rates of job creation, it is considered that an average rate of at least 5,000 jobs per year is utilised to inform housing provision.
iii. The South West Communities Plan "The Way Ahead" recognises that although the sub region makes the strongest contribution to GDP of the English Core Cities, it still does not realise its full economic potential. With four universities and other initiatives embracing enterprise and innovation, there is a high degree of potential that can make a significant contribution not only to the region, but to the national economy.
iv. Vision 2026 envisages the West of England as one of Europe's most competitive regional economies, which has closed the gap between disadvantaged and other communities; has rising living standards and a buoyant economy that competes internationally, based on innovation, knowledge-based businesses, a highly skilled work force, and the diverse cultural and other resources of the sub-region.
v. Key economic development priorities should be focused around the following:
· investment in key sectors, especially knowledge-based businesses including aerospace and advanced engineering; ICT; media and creative; professional and business services; tourism; retailing; construction and environmental technologies;
· realising the potential of key development sites and locations, including new opportunities for securing business investment; expansion of the Portbury Dock and Bristol International Airport, and related business development;
· maintaining and developing the centres of Bristol, Bath and Weston-super-Mare as vibrant business and multi-activity centres;
· facilitating business start-ups and small business development
vi. Strategic locations to accommodate additional growth include:
· Bath City Centre
· Bath Western Riverside (regeneration area)
· Bristol City Centre
· South Bristol (including Hengrove Park)
· Weston-super-Mare (Town centre and urban extensions)
· Avonmouth, Severnside and Royal Portbury
· Emerson's Green (including the Science Park)
· North Bristol and south of the M4 Motorway
· Urban extensions to the South West, South East and North East of Bristol
5.1.5 Providing sufficient housing
i. In order to meet the needs of the existing and growing population, address issues of housing affordability, possible differences in job growth forecasts and help minimise long-distance commuting, provision should be made for at least 100,000 dwellings within the West of England over the period 2006-2026.
ii. Provision should be made for at least 70,750 dwellings at Bristol, at least 7,000 dwellings at Bath and up to 11,500 dwellings at Weston-super-Mare between 2006 and 2026. Outside of the above three urban areas but within the remainder of the administrative areas of the three Unitary Authorities, housing provision at the smaller settlements and rural areas between 2006 and 2026 should be at the following levels: Bath and North East Somerset about 3,500 dwellings; at North Somerset about 5,300 dwellings and at South Gloucestershire about 2,050 dwellings.
iii. LDDs should seek to achieve at least 30% of affordable housing across the sub region. The proportion of affordable housing could, however, rise to 60% in areas of particular need, where it can be clearly evidenced.
5.1.6 Development Distribution
i. The overall priority for the West of England will be to maintain and improve the attractiveness of the urban areas as places in which people wish to live, work, and visit and invest. This should take place through a process of urban renaissance to develop balanced, vibrant and sustainable communities with a high quality of life. Achieving this will require the restructuring of land uses and transport networks to meet physical, economic and social changes; reinforcing the role and function of city, town and district centres; creating new mixed residential and commercial districts; promoting regeneration in areas of multiple deprivation; improving education, health, and cultural provision; improving environmental quality; reducing the need to travel and improving accessibility.
ii. The Green Belt surrounds and separates Bristol and Bath and has an essential role in helping to achieve more sustainable patterns of development. A strategic review of the three Green Belts across the region has been undertaken to determine their general extent (section x) which specifically for the West of England focused on the following:
· check the unrestricted sprawl of the Bristol urban area and Bath;
· prevent neighbouring towns from merging into one another, by maintaining the physical separation and distinct identities of the Bristol urban area, Bath, and other settlements in the sub-region, in particular the area between the two cities;
· safeguard the countryside from encroachment;
· reconciling the Green Belt designation surrounding Bristol International Airport and Portbury Docks and their economic contribution in delivering the West of England's vision;
· preserve the setting and special character of historic cities and towns, including the World Heritage Site of Bath;
· assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
iii. Studies to date undertaken by the strategic planning authorities have identified the potential for at least 65,000 dwellings within the sub-region's existing urban areas by 2026. Whilst such a strong contribution from the urban areas is welcomed in the strategy, adding to its sustainability, the Regional Planning Body consider that increased densities and a more innovative approach, akin to the Mackay vision at Plymouth, could increase this urban contribution by at least 7,500 dwellings. Taking into account commuting patterns between Weston-super-Mare and Bristol, the additional increase in urban concentration should be primarily focused at Bristol, complemented by a Bath.
iv. Taking into account the scale of growth that can be accommodated within the urban areas against the overall requirements, meeting the overall housing provision will therefore require, in addition to an urban regeneration strategy, a number of well planned urban extensions, incorporating the conclusions of the Green Belt review. These should contribute towards other important objectives, in particular the priority for the integrated provision of infrastructure and development to improve communications within and around south Bristol and to provide new links between the M4, south Bristol, the airport, the M5 and Weston-super-Mare.
v. Development within the sub-region should be focused on the Bristol urban area, as the region's major location to realise growth in economic activity and housing provision. Sustainable urban extensions to Bristol should be developed, immediately adjoining the south west (about 9,000 dwellings), south east (about 6,000 dwellings), north east (about 15,000 dwellings) and north of the Bristol urban area (about 6,000 dwellings) in conjunction with the provision of necessary infrastructure. Such urban extensions should be planned and developed as sustainable communities which deliver a high quality of life through high standards of design and access, protect and maintain environmental assets and landscape setting, and provide the physical and social infrastructure required.
vi. Provision for significant economic growth and housing at Weston-super-Mare and Bath should reflect their future potential, environmental factors and the need to address problems associated with commuting by improving the balance between economic activities and housing provision. At Weston-super-Mare, urban extensions should accommodate mixed development, a new sustainable community, and transport infrastructure improvements. A mixed development urban extension to the south of Bath of about 1,000 dwellings has identified to provide the range of housing and employment requirements that cannot be accommodated within the urban area. The precise location and composition of this urban extension should come forward through the LDD process, taking into account environmental and landscape constraints, World Heritage Site status, transport implications and incorporating the conclusions of the Green Belt review.
vii. Within the West of England several wards appear as the most deprived in the region, with Bristol having the largest concentration of deprived wards (as measured on the Index of Multiple Deprivation) receiving European Objective 2 status. The spatial development strategy for the area should address this disadvantage as well as provide for a growing economy and increasing numbers of households. Access to employment by residents of deprived wards in the City is a major concern which public and private sectors are working together through the Partnership to address. In addition, Weston-super-Mare has a concentration of deprivation in certain wards, and initiatives to boost local job growth should assist to redress these imbalances.
5.1.7 Delivering the Spatial Strategy for the West of England
i. Implementation of the proposals for the sub-region will depend on commitments from national, regional and local government, together with the private sector, to provide investment in infrastructure and services (including affordable housing) that is in phase with the demands of development and that addresses existing deficiencies.
5.1.8 Transport
i. Significant improvements in transport infrastructure in the West of England are essential for the continued economic and social success of the region and the sub-region. Transport investment in the West of England should reflect the sub-region's key role in delivering regional sustainability objectives and the pivotal role of its transport infrastructure in the region. Major investment is required both to address the under-investment in transport over previous years and to provide the foundation for future high levels of growth.
ii. Conclusions from the Greater Bristol Transport Study indicate the following will be important in delivering the vision:
· ongoing investment in public transport, walking and cycling provision;
· demand management measures;
· significant development of the heavy rail network;
· strategic rapid transit network;
· selective additional strategic highway capacity to serve business investment and regeneration in South Bristol and West-super-Mare and to improve access to the airport;
· selective additional strategic links to motorways and other trunk route networks;
· bus showcase routes along strategic corridors;
· major park and ride improvements;
· development of a guided bus (streetcar) network;
· significantly enhanced interchange facilities.
5.1.9 Other Infrastructure
i. The development strategy for the West of England will require additional investment in social and community infrastructure including provision of health, education, and sport, recreational and cultural facilities commensurate with an increase in the population.
· substantial investment in coastal defences is expected to be necessary to enable the economic potential of Avonmouth/Severnside to be realised;
· within the sub region major investment in new waste management facilities will be required to reduce landfill dependency, achieve greater local self-sufficiency and respond to economic and population growth.
5.1.10 Key Diagram - West of England
To Follow