SEG Home > Green Belt (Saltford)
NOTE: The successful 2 year defence from 2012 to 2014 by the community of Saltford against an attempt by the developer Crest Nicholson to build on Saltford's Green Belt south of Manor Road is recorded on a special archive page.
SEG submits its response to B&NES Local Plan Options
On 11th December 2018 SEG submitted to B&NES Council its response to the B&NES Local Plan Options consultation. We have reported previously concerning the similar response on 4th December from Saltford Parish Council produced jointly with SEG - that can be seen at the end of this news item.
Key points in SEG's detailed response included the following:-
- SEG has supported the request from SPC for (i) discussions with B&NES before there is any serious consideration of putting any parcel of Saltford's Green Belt into the draft Local Plan for development, and (ii) SPC's request for consultation from B&NES Council on the layout plans for the relocated Avon Valley Adventure and Wildlife Park in the proposed North Keynsham Garden Community Strategic Development Location (SDL).
- SEG reminded B&NES Council that in March 2014 the Secretary of State for Communities and Local Government refused planning permission for 99 new dwellings south of Manor Road for the National Planning Policy Framework reasons that we repeated. Like SPC, SEG made the point that there is no evidence or reason to suggest that the situation had changed to make that or other sites or portions of Green Belt sites in Saltford including any that are adjacent to Keynsham, acceptable or suitable for development.
- Taking a constructive approach, SEG offered to provide some level of professional pro bono advice to support the ecological design of the relocated Avon Valley Adventure and Wildlife Park in the proposed North Keynsham SDL. In addition to other recommendations we asked, for example, that the relocated park be planted only with native species ecologically appropriate to NE Somerset.
- SEG made the case that Keynsham, like Saltford, should retain its own Green Belt buffer in the Local Plan.
- SEG, like SPC, did not agree with the proposed removal of safeguarded status for the two former Green Belt sites at Keynsham East as part of the North Keynsham SDL. SEG recommended that if the North Keynsham SDL is adopted it should be carefully developed using an incremental approach with the two safeguarded East Keynsham sites developed last, if at all, in response to need, not demand, for new housing. That approach can help ensure transport and other infrastructure is coping satisfactorily with new developments added in increments before additional and relatively significant volumes of new houses are built.
A website version of SEG's response can be downloaded here: SEG LP Options response 11.12.2018 (pdf opens in new window).
The Saltford Parish Council agreed response can be downloaded here: SPC LP Options response 4.12.2018 (pdf opens in new window).
The map above shows all 9 of the Saltford Housing and Economic Land Availability Assessment (HELAA) sites that were considered/assessed in order to inform preparation of the B&NES Local Plan Options for development. Those 9 site are all on Saltford's Green Belt and were submitted to B&NES by developers/land owners following a call for sites in early 2017. Our campaign's objective is to make sure those sites stay out of the Local Plan, as they are unsuitable on planning and sustainable development grounds for development, and to protect from development the Green Belt surrounding Saltford.
A larger version of the above map together with a short briefing note on the B&NES Local Plan and West of England Joint Spatial Plan process that was discussed at our 8th October AGM can be downloaded from the link below. Please note that the dates within the note are all subject to change.
Green Belt briefing for 08.10.2018 AGM (pdf)
The dedicated B&NES Local Plan web page can be found from this link: B&NES Local Plan 2016-2036.
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SEG Green Belt Campaign
SEG launched a new Green Belt Campaign after its AGM on 8th October 2018 to respond to the potential threat posed to Saltford's Green Belt by the Local Plan and speculative planning applications that may be anticipated in connection with the Local Plan process. Updates on the campaign will feature regularly on our home page and information will also be posted here.
An email was sent to SEG members on 27th October 2018 encouraging members who are able and available to assist the campaign to contact SEG's Chairman Phil Harding to volunteer to join our Campaign Team. The Campaign Team will be our "arms and legs" on standby to deliver leaflets to households and undertake other ad-hoc supportive tasks that may arise.
You can read the text of the article "Why the Green Belt in B&NES is so important" by our Chairman Phil Harding in the 5th December 2018 edition of The Week In here: Green Belt article (pdf opens in new window).
Local Plan (2016-2036)
Saltford's Green Belt: B&NES Local Plan & HELAA Update
Here we give an update on the forthcoming B&NES Local Plan that could have a significant impact on Saltford's Green Belt.
The map above shows all 9 of the Saltford Housing and Economic Land Availability Assessment (HELAA) sites that are being considered/assessed in order to inform preparation of the B&NES Local Plan. Those 9 site are all on Saltford's Green Belt and were submitted to B&NES by developers/land owners following a call for sites in early 2017.
Through the plan-making process B&NES is required by government to consider all 'reasonable alternatives' in meeting housing needs. The primary purpose of the Local Plan 2016-2036 is to identify and allocate sites to meet the housing and economic development requirements established by the West of England Joint Spatial Plan (JSP).
The B&NES Housing and Economic Land Availability Assessment (HELAA) review feeds into the Local Plan process. Following the call for sites by B&NES in early 2017, HELAA will identify which of those sites would fit with being allocated for housing according to B&NES Council's assessment.
The B&NES website, Housing Land Supply page, lists and maps 9 sites on Saltford's Green Belt that have been submitted by developers/land owners. Saltford Parish Council (SPC) submitted its site assessment for those 9 sites response in July 2018. SEG members will be aware that SPC shares SEG's policy to protect from development the Green Belt surrounding Saltford.
It is important to recognise that although 9 sites have been put forward by developers/landowners in response to the HELAA call for sites it does not follow that B&NES Council will accept all, some or any of those as suitable sites for development, but it has to assess them.
In winter 2018/19 the draft HELAA and the draft Local Plan options document will go public and then after drafting during summer 2019 the draft Local Plan is scheduled to go public for consultation in autumn 2019. At that stage and following consideration of comments on the options document B&NES Council will set out its preferred strategy/distribution for development and identify sites for proposed allocation.
From winter 2018 respondents (including the general public but developers also) when making comments on the Local Plan options document will be able to refer to the draft HELAA. That is why SPC's prior response in July 2018 was an important stage in the early drafting process before the draft HELAA is published for public consultation.
This has brought out into the open the clear intention of developers to try and build on Saltford's Green Belt, regardless of the negative implications for the local community and local ecology; it is difficult to think of anywhere more unsuitable and inappropriate for new housing in B&NES. However it is important to recognise that B&NES Council has to be seen by government to transparently test and consult on alternatives - that is the purpose of the Local Plan options document in order to inform the preferred approach in the draft Local Plan.
Because the Local Plan sets land allocations for housing until 2036, Saltford as a community needs to make a robust and appropriate response if it is to protect the Green Belt that surrounds our village. SEG takes the sustainable development view that there are no genuine 'exceptional circumstances' that could support a case for building on Saltford's Green Belt when taking account of ecological, environmental, transport, economic, social and employment factors. It is our strong wish that sites in Saltford's Green Belt are not identified for potential development in the draft Local Plan.
Our membership survey in February 2018 revealed that of SEG's activities, protection of the Green Belt interested our members the most. We hope therefore that members will understand why responding to consultations etc. on the Local Plan and other lobbying activity that goes on behind the scenes will be a priority for SEG in the coming months.
HOW YOU CAN HELP
If you want to help SEG defend the Green Belt at this important stage in the local strategic planning process do re-visit our website periodically, watch out for SEG emails to members and also SEG announcements on our Facebook page (follow us there if you are on Facebook).
Updated September 2018
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HELAA: SEG makes case to B&NES that our Green Belt is not appropriate for development
B&NES Council is carrying out a Housing and Economic Land Availability Assessment (HELAA) review and SEG submitted its response to the B&NES report on 9th November 2017. HELAA is required in order to identify and assess land that could be considered for allocation in the Local Plan (previously known as the Core Strategy Review) that will cover the period 2016-2036. The primary purpose of the Local Plan 2016-2036 is to identify and allocate sites to meet the housing and economic development requirements established by the West of England Joint Spatial Plan (JSP).
The council undertook a call for sites (CFS) between January and March 2017 requesting land to be identified and submitted to the council for assessment through the HELAA process. Anyone could submit land for consideration, but part of the assessment relates to the availability of the land and therefore land normally needs to be owned by someone who is willing to develop it or to sell the land to a third party who is willing to do so. Apart from availability, it was stated that the assessment would consider both the suitability and the achievability of land.
As SEG predicted, developers have identified Green Belt land on the south and west side of Saltford that they would like to build on. SEG and the Parish Council have responded accordingly, SEG on 9th November, and both responses were strongly against such development for a range of planning and sustainable development reasons including traffic congestion, new developments should be close to the sources of employment to reduce the need to travel for commuting and that it is unsustainable to build on the Green Belt which would be contrary also to national planning policy (known as NPPF).
Furthermore at the public meeting held at Saltford Golf Club on 1 December 2016 the Leader of B&NES Council, Tim Warren, said that the "current B&NES administration had no intention to allow housing development on Saltford's Green Belt in the Joint Spatial Plan".
You can download SEG's HELAA response here:-
On 9th January 2018 SEG submitted its response to B&NES to the B&NES Local Plan 2016-2036 Issues & Options document.
SEG said it supported and was in full agreement with the response from Saltford Parish Council that was agreed by the full Parish Council on 2 January 2018. The response underlined and gave reasons for protecting the Green Belt and raised concerns over transport issues and stated that it was essential that appropriate and necessary transport infrastructure changes are made to reduce vehicles use on the A4 before any additional housing is planned for the area that would in effect place more vehicles on the A4 through Saltford or on other pinch points on the A4 route between Bristol and Bath.
In addition to comments on affordable housing, the protection of archaeological sites and the importance of the rural villages close to Bath, SEG added a further explanation behind why the Green Belt needs protection as follows:-
81% of B&NES is farmland compared to the national average of 57% yet only 5% of B&NES is natural or semi-natural land (heathland, natural grassland etc.) compared to a national average of 35% (data source: Dr Alasdair Rae, University of Sheffield, using Co-ordination of Information on the Environment (Corine) land use codes, 2017). Farmland requires the ecosystem support (e.g. habitat for pollinating insects) of surrounding Green Belt and natural/semi-natural land to function. It would be irresponsible not to protect B&NES' natural/semi-natural land that underpins the economy of the B&NES and wider West of England area and our future food security in a changing climate made more critical by unmanaged population growth.
Updated January 2018
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Joint Spatial Plan (JSP) &
Joint Transport Study (JTS)
SEG submits statement on North Keynsham SDL to West of England JSP Public Examination
On 14th June 2019 SEG submitted its formal statement on the proposed North Keynsham Strategic Development Location (SDL) to the West of England Joint Spatial Plan Public Examination (Matter 7.1). SEG expects to attend the hearing in September 2019 to make and support its case for protecting the Green Belt between Keynsham and Saltford in the context of the proposed North Keynsham SDL.
The key summary points of SEG's statement are as follows:-
The proposed North Keynsham SDL does not represent sustainable development. If however this SDL is to proceed the following mitigating factors are recommended:-
- An incremental approach be taken to ensure (i) transport and other infrastructure is coping satisfactorily with new developments added in increments before additional and relatively significant volumes of new houses are built (i.e. an "infrastructure first" approach allied to intermediate tests to ensure unintended negative consequences have not arisen and that any problems are resolved before making matters worse), and (ii) the genuine need for continued new developments is tested and proven during the plan period.
- The relocated Avon Valley Wildlife and Adventure Park remains as designated Green Belt land to protect against future inappropriate development and to help maintain Keynsham's Green Belt buffer.
- New housing developments within the SDL and the relocated Avon Valley Wildlife and Adventure Park should be designed so as to contribute to a "significant environmental gain" (rather than a paltry net environmental gain) to help local ecology and wildlife recover from the significant losses of recent decades. Such an approach provides an opportunity to be an example of excellence in meeting environmental needs first to underpin social and economic needs.
- All development associated with this proposed SDL should meet the B&NES Council March 2019 cross-party decision to declare a climate emergency and that "B&NES is well-placed to champion both rural and urban decarbonisation through renewable energy, energy efficiency, smart energy development, zero carbon homes, local & sustainable food, sustainable travel, carbon sequestration".
- The SDL should be Local Plan led (i.e. by the planning authority taking account of local democratically made decisions and agreements) and not developer led.
You can download a copy of SEG's 3-page submission statement, that sets out our case behind the key points listed above, from our website here:-
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Joint Spatial Plan submitted to Secretary of State on 14.4.2018
The West of England Joint Spatial Plan that sets out the policies and principles "for determining the most appropriate and sustainable locations for future development to meet its housing, employment and transport
needs for the next 20 years, to 2036" was submitted to the Secretary of State on 14 April 2018. The JSP will now be examined for its compliance with statutory requirements and on its soundness by Government Inspectors.
All submission documents are available at www.jointplanningwofe.org.uk. A copy of consultation responses can be found at www.jointplanningwofe.org.uk/.../listRepresentations.
No Strategic Development Locations have been identified for Saltford but we are aware that developers are lobbying for development on Saltford's Green Belt in the context of the B&NES Local Plan which will identify and allocate sites to meet the housing and economic development requirements established by the West of England JSP; SEG and Saltford Parish Council are making representations concerning the B&NES Local Plan accordingly (for Local Plan see higher up this page).
Only those who have submitted evidence will be able to attend the JSP hearings. The precise date for the opening of any formal hearing part of the examination into the JSP will be decided by the Inspectors. It is currently anticipated that the hearings will begin in autumn 2018.
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SEG submits response to Joint Spatial Plan
On 9th January 2018 SEG submitted its response to the West of England Partnership on its proposed Joint Spatial Plan. Although Saltford's Green Belt is not identified for development in the JSP, we are aware that developers are lobbying for its inclusion. SEG's response was that the JSP was unsound on sustainable development policy grounds for the following reasons:
Local Authorities are not given specific powers and responsibility to build affordable housing. Relying on the private sector to deliver the affordable housing that is required will not produce the desired outcomes. That has been the case hitherto where maximising a financial return on investment has been the main objective rather than meeting genuine housing needs in locations close to employment and that minimise the need for road transport for access to work, services and leisure facilities.
A continuation of the 'predict and provide' approach is very disappointing; no measures are proposed to affect predictions and thereby reduce the need for such a high volume of new housing during the JSP timescale is a cause for concern.
An holistic approach to management of land as an ecological resource to be highly valued is missing. The main example of this is that food security is ignored at the expense of housing provision on undeveloped land. Compensatory habitat for replacing ANY Green Belt and other natural land earmarked for new housing therefore must be provided for the JSP to be genuine sustainable development.
SEG then described B&NES as an example: 81% of B&NES is farmland compared to the national average of 57% yet only 5% of B&NES is natural or semi-natural land (heathland, natural grassland etc.) compared to a national average of 35% (data source: Dr Alasdair Rae, University of Sheffield, using Co-ordination of Information on the Environment (Corine) land use codes, 2017).
Farmland requires the ecosystem support (e.g. habitat for pollinating insects) of surrounding Green Belt and natural/semi-natural land to function. It would be irresponsible not to protect B&NES' and the West of England's natural/semi-natural land that underpins both the West of England's economy and our future food security in a changing climate made more critical by unmanaged population growth.
SEG also described what was required to overcome the deficiencies in the Local Plan:-
1. An overarching commitment to only build on Green Belt and natural/semi-natural land which is close to centres of employment, key services and leisure facilities, as a last resort, in exceptional circumstances and only after:-
- all brownfield sites have been fully developed (with the use of compulsory purchase orders where necessary to bring forward suitable brownfield sites for development);
- the opportunities to re-develop existing sites have been explored and used;
- representation to central Government to take measures to manage the UK's population growth to sustainable levels so that the UK's food security can be protected and enhanced, not weakened;
- a thorough investigation is carried out into the options for constructing one or more garden cities rather than destroying or disrupting several existing rural and semi-rural communities;
- compensatory habitat is identified, created and afforded appropriate safeguards and protection from future development.
2. Taking account of 1. above, a policy to encourage and enable West of England local authorities rather than private sector developers to deliver affordable housing, sub-contracting construction to the private sector as necessary.
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SEG responds to JSP and JTS consultations
SEG submitted its response to the West of England's consultation on the Joint Spatial Plan (JSP) and Joint Transport Study (JTS) on 10th December 2016 before the 19th December 2016 deadline for submitting comments via https://www.jointplanningwofe.org.uk.
Some of the key comments included in SEG's response were as follows:-
Joint Spatial Plan (JSP)
The proposed JSP fails to empower or take account of the emerging role that WoE Councils could have in building housing themselves rather than private sector developers. WoE Councils would thereby determine timescales and location sequencing of their own choosing and in line with improved transport infrastructure.
There is an insufficient emphasis on the urgent need to drastically reduce car commuting.
Joint Transport Study (JTS)
Insufficient investment in heavy rail solutions has been proposed whilst too high a priority is given to road building (that simply attracts more car use) despite the lack of space and the need to transfer commuting away from the car. Attention should be been given to investigate the possibility of additional use of the existing disused rail corridors in the region, for example the Avon Valley railway line currently shares the Bristol-Bath cycle path with cyclists. A study could be made to see if this could be extended in both directions to provide a modern LRT (Light Rail Tram/Train) alongside a cycle way.
New road proposals represent poor value for money and can create new or worse problems further along the commuter route/corridor compared to improved public transport infrastructure for tackling peak time congestion. They can also have negative impacts on established communities without addressing the cause of bottlenecks.
Saltford Environment Group shares Saltford Parish Council's opposition to the proposed bypass at Saltford for several reasons including loss of the Green Belt, the negative impact on the environment, local commerce, and the integrity of Saltford as a place. Furthermore it is important that the proposed bypass route shown as a blue line south of Saltford is removed from the next version of this JTS document. The publication of a route line/option or series of options will cause a housing blight for a significant proportion of Saltford that could last as long as the duration of the JTS period.
A strategic look at all the transport options for Saltford and the surrounding area is required but does not need to show a Saltford bypass route on a map when there are no firm plans for a bypass and it is being considered as one of a number of traffic congestion mitigation measures.
SEG questions the proposal to put an LRT scheme on an existing road corridor like the A4 through Saltford, particularly when other options that do not affect road space need to be considered first, e.g. an LRT sharing the Bristol-Bath cycle path with cyclists as partially happens now with the Avon Valley Railway. Investment in heavy rail can provide a better, longer term solution. An LRT scheme on the A4 through Saltford would reduce road space for existing car-based commuters when there are better transport solutions that can be delivered much more quickly such as re-opening Saltford station.
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SEG responds to B&NES Core Strategy consultation by highlighting local Green Belt policies
Keep Saltford's Green Belt green!
In response to the B&NES Council review of its Core Strategy and consultation on the proposed content, scope and programme for the Core Strategy Review for the period 2016-2036, SEG has submitted the following response on 7th December to the question "Do you have any specific observations to make on the Core Strategy review?" :-
The public commitment on 1st December 2016 by the Leader of B&NES Council, Cllr Tim Warren, at the public meeting in Saltford about a proposed bypass that there was not any housing development planned for Saltford is welcomed by Saltford Environment Group (SEG). SEG also supports Cllr Tim Warren's opposition stated at that meeting to the use of any of Saltford's Green Belt land for housing development.
Cllr Tim Warren's statement is in line with the fact that there is no political mandate or permission from the residents of B&NES or Saltford to allow any loss of the Green Belt to development. The ruling Conservative administration at B&NES Council was elected in May 2015 on a manifesto to defend the Green Belt from development. The Core Strategy Review should not therefore propose, suggest or even hint at housing development on any parcel of Green Belt land in Saltford as that would be contrary to the declared land use planning policy of B&NES Council.
Following this initial consultation, from 7th November to 19th December 2016, the Core Strategy Review will allocate strategic sites at locations identified in the West of England Joint Spatial Plan (JSP) and other "development opportunities" will be identified and allocated - hence SEG's reminder to B&NES Council of the Council's own declared policies and the political commitments made by its elected members to the local electorate. B&NES Council will also take the opportunity to look again at other policy areas such as renewable energy targets and what infrastructure is needed to support additional development.
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Standing room only at the Saltford bypass public meeting
Some of the bypass meeting audience on 1st December 2016.
Approx. 200 residents attended the public meeting at Saltford Golf Club on the evening of 1st December. This was arranged at short notice by Saltford Parish Council to give residents an opportunity to hear about the proposed bypass as illustrated in the West of England Joint Transport Study "Transport Vision" document which has a very short consultation period from 7th November to 19th December.
On the panel stating their position on a bypass and taking questions from residents were Cllr Tim Warren, Leader of B&NES Council; Cllr Tony Clarke, B&NES Cabinet Member for Transport; Cllr Francine Haeberling, Ward Councillor for Saltford (Cons); Cllr Chris Warren, Chairman of Saltford Parish Council; and Duncan Hounsell, representing B&NES and Saltford Liberal Democrats. The meeting was chaired by independent chairman and Saltford resident, Dick Bateman.
Cllrs Tim Warren and Tony Clarke were emphatic that the line on the map showing a bypass route south of Saltford was illustrative only and there were no plans for a bypass on any particular route around Saltford. It was being considered in only general terms at this stage as part of the mix of transport solutions to help alleviate the traffic congestion on the Bath-Bristol transport corridor as part of the Joint Transport Study which was intended to cover a 20 year period from 2016 to 2036.
The majority of questions from the floor expressed concerns at the potential impacts on Saltford and the potential for infill housing on the Green Belt from a bypass. The need for evidence based information on the different options or solutions before the community was asked to express a firm opinion was also emphasised by several residents.
A number of residents in the audience and the panel members from Saltford asked for the next published draft of the transport vision to not include any indicative line for a Saltford bypass. It was strongly felt that any indicative line showing a possible bypass would put an unnecessary long term housing and planning blight on a large part of Saltford.
Cllr Tim Warren promised to organise another public meeting in Saltford with the relevant transport officers present so that a more informed discussion could be held on the various transport options under consideration. He said that if the residents of Saltford do not want a bypass, then a Saltford bypass would not be built. He also said that the current B&NES administration had no intention to allow housing development on Saltford's Green Belt in the Joint Spatial Plan. Duncan Hounsell said the Liberal Democrats would seek to remove a Saltford orbital road from the proposed Transport Strategy when the opportunity arises should the proposal find its way into the final document.
The timing on any future public meeting, whether hosted by the Parish Council or B&NES Council, would be dependent on timing with the next draft Joint Transport Study "Transport Vision" document. In the meantime the Parish Council would decide its response to the current consultation at its meeting on 6th December.
The four west of England councils' (Bath & North East Somerset, Bristol City, North Somerset and South Gloucestershire) short consultation period on the Joint Spatial Plan and Joint Transport Study from 7 November to 19 December 2016 has been a cause for concern when the plans have such major implications. These plans set out a prospectus for sustainable growth to meet the area's housing and transport needs for the next 20 years. However there should be further opportunities to comment on future drafts of those plans.
Residents can see the plans and comment online at www.jointplanningwofe.org.uk (UPDATE - this stage of the consultation has closed).
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NOTE: We are publising updates on the Joint Spatial Plan (JSP) and Joint Transport Study (JTS) negotiations and consultations on our home page - news section.
The current JSP timetable is as follows (the Joint Transport Study is expected to be completed in parallel with the JSP) after much slippage:-
- Autumn 2018
Questions from HMG Inspector
- Spring/Summer 2019
- Autumn 2019
Report by Government Inspector & Adoption
(i) Background and (ii) Policy paper submission from SEG
The West of England's Joint Spatial Plan and Transport Study (www.jointplanningwofe.org.uk) will
"set out a prospectus for sustainable growth that will help the area (Bristol, North Somerset, South Gloucestershire and Bath & North East Somerset) meet its housing and transport needs for the next 20 years."
Estimates state that the area needs at least 85,000 new homes by 2036, that is 29,000 more than the number already planned in Core Strategies, as well as the transport and other infrastructure needed to support that level of growth.
In B&NES, the B&NES Core Strategy (2014-2029) was agreed in July 2014 after lengthy negotiations. Once agreed the JSP (2016-2036) will in effect override the B&NES Core Strategy for determining the location and size of new housing developments in B&NES until 2036. The B&NES Core Strategy is being reviewed and replaced by a new Local Plan 2016-2036 simultaneously so that its timespan will be extended to match that of the JSP.
Policy paper submission by SEG
On 27 January 2016 SEG submitted a policy paper 'Very special circumstances and the Green Belt' to the West of England Partnership as its response to the consultation for 'Issues and Options' in the West of England Joint Spatial Plan. The Green Belt is a much valued designation the protection of which is increasingly vital. The paper covers these topics:-
- Population growth, food security and protecting our 'natural capital'
- Where do we put new housing?
- Green Belt planning policy
- Democracy and political considerations in B&NES and Saltford
- Sustainable development
You can download SEG's paper here:
'Very special circumstances and the Green Belt' (pdf)
Last updated March 2017 (minor update re. B&NES Local Plan, September 2018)
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Threat to Saltford's Green Belt from WoE Joint Transport Study proposal for a bypass
The West of England Joint Transport Study (JTS) published on 7 November 2016 describes the Bath to Bristol corridor as having "a high travel demand across car, bus and rail modes". It also "experiences severe congestion throughout the day, and access to and from South Bristol affects people's access to job opportunities, and restricts inward investment and economic regeneration."
The JTS is proposing to introduce a Rapid Transit public transport corridor between Bath and Bristol, to complement improvements on the existing rail corridor, and provide for a "wider range of trip options". This is described as possibly "bus-based but the ambition is for a light rail (tram) solution along the A4 corridor... delivered as a package with highway investment including a Saltford Bypass (see blue line close to the southern edge of Saltford's housing boundary on the above map from the study document), Callington Road (A4174 in Brislington) Link and better links between the A4 and A37 roads".
The study claims the highway schemes would provide new routes for through traffic enabling existing roads to be better used for Rapid Transit, public transport and cycling. Movements between the A4 and A37 could be either improvements to existing roads, new highway or a combination of the two.
The JTS is also proposing further park and ride sites and better cycling facilities to serve both Bath and Bristol, a new road link between the A36 and A46 to the east of Bath (which would help tackle congestion in city centre), and possible further improvements on the A37 into Bristol from the south.
The case against a Saltford bypass
In line with SEG's previously declared policies on a bypass (see "A road bypass for Saltford?" below) the case against a Saltford bypass as proposed in the JTS is considerable and is as follows:-
- this would create an unacceptable loss of the Green Belt (going against promises made by the manifestos of the elected Councillors controlling B&NES Council in the May 2015 local election);
- release of the existing road capacity constraint at Saltford is likely to lead to more vehicles using the new bypass than use the existing A4 thus creating more commuter traffic than before and creating more congestion backing up down the Keynsham bypass from Hicks Gate roundabout;
- infill development (as the housing development boundary would almost certainly move out to the bypass route) and ribbon development along the outside edge of the bypass would be difficult for planners to resist or prevent thus resulting in more loss of Green Belt, more traffic congestion and Saltford changing from a rural village to a town;
- a Light Rapid Transit (LRT) system on the A4 would reduce road space for existing car-based commuters when there are better transport solutions that can be delivered much more quickly such as re-opening Saltford station;
- if a LRT is an attractive option then better alternative routes should be seriously investigated such as use of the existing LMS (Sustrans) route for an LRT alongside the cycle path;
- the Greater Bristol Strategic Transport Study by Atkins in 2006 said a bypass would "not produce an effective economic performance". Priced then at £72M (2006 prices) it said the release of the capacity constraint at Saltford would create additional traffic in Bath producing further congestion in the area and would achieve only modest time savings between Keynsham and Bath;
- local shops in Saltford would be at risk as a result of losing passing trade;
- the proposed route bypass on the southern edge of Saltford's housing development would result in a majority of Saltford residents being encircled by two main roads resulting in higher levels of noise and air pollution putting a blight on the local housing market;
- a bypass would destroy existing footpaths and bridleways;
- evidence of Roman and Bronze/Iron Age occupation on the southern side of Saltford discovered by SEG and BACAS in 2015 and 2016 requires a full archaeological study and appraisal of Saltford's Green Belt before any consideration to put at risk the local community's heritage by locating a bypass in that area;
- in the 21st Century simply building more roads is not a sustainable solution to traffic congestion. An integrated range of sustainable solutions is required including the re-opening of Saltford station on the existing station site that can be done relatively quickly. Building more roads that increase overall road traffic with higher carbon and other polluting emissions whilst creating traffic problems elsewhere just makes matters worse.
The Parish Council's view
At its 1st November meeting Saltford Parish Council agreed the following statement which will form part of its response to the JTS consultation:
"Saltford Parish Council is opposed to a by-pass at Saltford, being detrimental to the Green Belt, the environment, local commerce, and the integrity of Saltford as a place. Saltford Parish Council notes the 2006 Greater Bristol Strategic Transport Study, which concluded that a by-pass at Saltford does not provide strategic benefits and does not represent value for money."
We publish updates on the JTS and JSP negotiations and consultations on our home page - news section.
The website where West of England Joint Transport Study information and where comments including objections to proposals in the JTS can be made (until 19.12.2016) is:
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Joint Spatial Plan (JSP):- SEG and Saltford Parish Council
SEG is and has been working closely with Saltford Parish Council to help formulate the Parish Council's response to the consultation for 'Issues and Options' in the West of England Joint Spatial Plan. At its meeting on 5th January 2016 the Parish Council agreed its response which was submitted during January. The following are the key points of the submission:-
"New housing needs to be located close to jobs"
Saltford Parish Council is concerned that the continuous addition of new housing developments to existing settlements in towns and rural areas to meet the projected housing needs of Bristol and Bath will create many more problems than are solved for the region and its communities.
The resulting negative impacts include: more overloading of transport systems; reduced air quality arising from higher traffic volumes and congestion; local services put under increasing strain, loss of recreational green spaces; loss of Green Belt so that natural habitats including wildlife corridors are depleted; local tourism/leisure businesses put at risk; and agricultural land permanently lost for food production purposes. Those impacts underline why that approach is not sustainable development.
Saltford has the status of an Air Quality Management Area on part of the main A4 road through the village due to the traffic volumes it currently experiences leading to periodic levels of dangerously high NOx levels being reached; adding new housing developments and thus road transport in the area would exacerbate this existing problem. Furthermore the Issues and Options paper at paragraph 2.18 makes the transport case for not adding further housing developments to towns and rural areas (i.e. including Saltford) by stating that "there is an imbalance of jobs over resident workers in central Bristol and Bath and an imbalance of
workers over jobs in Weston-Super-Mare, the towns and rural areas with resultant unsustainable commuting patterns". In other words, new housing needs to be located close to jobs.
To prevent the piecemeal destruction of the West of England's open spaces and Green Belt over and above existing Core Strategies, we request that:
- the first priority should be to create affordable attractive housing on suitable brown field sites close to employment - with developers and architects competing to produce the best designs;
- the design and location of further new housing developments in the Joint Spatial Plan should avoid overloading towns and rural areas (by implementing 1); and
- Green Belt land in the West of England should be protected from development and recognised as a high value irreplaceable asset thus reflecting the Government's policy on protecting the Green Belt against urban sprawl (see section on Protecting the Green Belt below).
If the need (not demand) for new housing continues to outstrip the supply from brown field sites in the longer term, a region-wide consultation could be held on whether a new "Garden City" would be appropriate and where it might be located. A new "Garden City" should be genuine sustainable development, i.e. a self-contained community surrounded by Green Belt, containing proportionate areas of housing, industry and commerce, green spaces and agriculture, yet with good public transport routes and access to Bristol or Bath.
"Protecting the Green Belt"
There are strong planning and sustainable development reasons for not building new housing developments on Green Belt land in the West of England. Building further new developments on the Green Belt will destroy much of what gives the region a rural and semi-rural character that has attracted people to live and work in the area. It would put at further risk the region's agricultural and tourism/leisure businesses and the wider ecosystem benefits that the Green Belt is increasingly relied upon to provide.
Furthermore, the Government has made it clear through several policy statements by DCLG Ministers that Local Plans should protect, not build on, the Green Belt even if it constrains the ability of some local authorities to meet their own housing needs [3 example statements from HMG Ministers were supplied].
Looking at Saltford specifically, the Saltford Placemaking Plan was produced (and is published on the Parish Council website) following community consultation in 2013.
The purpose of this plan is to complement the strategic planning framework provided in Bath & North East Somerset Council's Core Strategy. It provides an updated and refreshed planning policy framework for managing development in the Parish of Saltford.
The response also described why Saltford's Green Belt was unsuitable for housing development. Extracts from the Green Belt character assessment (Chapter 6) of the Saltford Placemaking Plan were provided including the specific planning reasons given by the Secretary of State that the proposed development on the fields south of Manor Road, the subject of the 2013 Planning Inquiry, would result in an unacceptable reduction of the Green Belt in that area. The Parish Council also posed some pertinent questions including:-
- Given the electorate's support for winning candidates in recent local and general elections who were opposed to development in the Green Belt, what mechanism does the Strategy have in place to ensure that any decisions that come out of the plan are democratically agreed and have the support of local residents?
- How will disagreements between the four Authorities be resolved?
- Given the benefits of providing affordable housing close to employment what is the strategy in respect of the location of affordable housing across the four authorities?
- What process will be included in the plan to ensure that land banking by landowners and developers does not affect the delivery of the target housing numbers outlined in the Plan?
- What mechanism does the report suggest is employed to ensure that brownfield sites are brought forward first before any Green Belt sites are considered?
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Saltford's Green Belt
The housing development area of Saltford is surrounded by Green Belt and the Cotswold Area of Outstanding Natural Beauty (AONB) on the eastern bank (Bath side) of the River Avon towards Kelston and the Round Hill. Saltford is also surrounded by the Community Forest of Avon area (N, W and S sides of the village).
The Parish Plan (2010) describes the local purpose and views about our Green Belt as follows:
"Saltford lies within the Bristol/Bath Green Belt which is how it has managed to keep its countryside setting, and there is a clear view amongst residents that this Green Belt surrounding the village should continue to be protected from erosion through housing development."
93% of respondents to the Parish Plan questionnaire circulated in September 2009 thought it was important to preserve the Green Belt around Saltford. This demonstrates that a key reason why people choose to live in Saltford is for the quality of the local natural environment and countryside. The habitat it provides
for local wildlife is also important and highly valued by residents.
If we wish Saltford to retain the character and size of a rural village (Saltford is classified as an 'R.1. Rural Settlement' in the B&NES Local Plan 2007), then the protection of our Green Belt is essential.
Against the background of a rising population and climate change it is also increasingly important that, for the ability of the local area to produce food for current and future generations, we protect viable agricultural land and natural/semi-natural land within the Green Belt. Farmland requires the ecosystem support (e.g. habitat for pollinating insects) of surrounding Green Belt and natural/semi-natural land to function.
The Green Belt has a valuable role in providing food and habitat for our wildlife and thus protecting the biodiversity that is so important for a healthy environment that in turn is essential for our quality of life whether we live in Saltford itself or in neighbouring towns and cities where recreational access to the countryside is equally important.
In view of all these factors, SEG's Committee has produced it's own set of core principles for how we respond to plans for any future proposals to develop on our green belt.
Green Belt: The Six Core Principles
Saltford Environment Group's Committee agreed the following policy statement incorporating six core principles on 15th January 2013.
We are of the opinion that the Green Belt land around Saltford should not be developed because:
- It is important to retain and sustain a sense of community for villages like Saltford. The creation of additional housing on Green Belt land around Saltford would set an unwelcome precedent leading to an urban sprawl merging Bristol with Bath, the destruction of the setting and special character of the area, and loss of community cohesion. This would seriously diminish the quality of life for the wider community, as well as the residents of Saltford.
- Traffic congestion requires sustainable solutions, not simply creating more roads that increase overall road traffic with higher carbon and other polluting emissions whilst creating traffic problems elsewhere.
- The protection of our 'natural capital', the natural environment and the biodiversity of wildlife that it supports, is essential for the health and well-being of present and future generations. It is important to retain and enhance attractive landscapes near where people live.
- Green Belt and agricultural land should be retained and protected for potential future food production purposes should that become necessary against a background of extreme weather due to climate change creating food shortages in the future.
- The existing services and infrastructure struggle to cope with heavy rainfall; further development would make matters worse.
- Central and Local Government have a duty of care to take a more long term and strategic approach by first identifying the future 'carrying capacity' of the UK and local regions. This must be done against a background of world population growth that is creating an ever growing demand for food whilst the increasing episodes of extreme weather in the UK and
worldwide due to climate change will reduce the UK's ability to feed itself or rely on imported food.
For these reasons we cannot accept development on our Green Belt as a matter of principle.
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Food Security and the Green Belt:
Who feeds Saltford, B&NES and the UK?
The food system must become sustainable...
It is essential that policy-makers address
all areas at the same time
'The Future of Food and Farming: Challenges
and choices for global sustainability'
The summer of 2018 shared with 2006, 2003 and 1976 was the hottest UK summer on record with temperatures in England for 2018 breaking all records according to the Met Office. But extreme fluctuations in our weather should not be unexpected and these can have drastic affects on food supplies and food prices. For example 2012 was a year of extremes for the UK's weather with 78 days of flooding and 95 days officially in drought. Likewise 2007 which also saw some of the most severe flooding in recent memory also started the year with hosepipe bans.
The persistent wet weather during 2012 (after the drought of 2011) resulted in total rainfall for the UK of 1330.7 mm, which is just 6.6 mm short of the record set in 2000. 2012 was the wettest year on record for England. The effect of drought followed by floods on UK food production was significant.
Defra figures show that the UK's imports of cereals and cereal preparations rose by £318M or 12.5% in 2012 (Dec '11 - Nov '12) following England's drought conditions in 2011. According to the NFU, in 2012 the UK's wheat production was down to the levels of the early 1980s. But in 1980 there were a lot less mouths to feed with a UK population, at 56M, 7M lower than in 2011 (63M).
The 2012 droughts in the US, as we had floods here in the UK, pushed up the price of wheat and maize, and led to the world's poor eating less. For England and Wales, the 2013/14 winter was the wettest since 1766 resulting, for example, in prolonged flooding on the Somerset levels affecting a significant area of agricultural land.
Clearly, extreme weather, fluctuating between prolonged periods of wet weather, heat waves and drought, arising from climate change makes a direct impact on the carrying capacity of the UK and can and will have a drastic effect on food supplies and food prices, i.e. food security.
Rather than waiting for a food supply crisis to occur in the UK before taking action when it may be too late, we should plan ahead now. You can download SEG's Food Security Information Sheet lower down this page.
We need to protect our agricultural land and make sure we provide sufficient headroom to take account of unmanaged population growth raising the demand for food whilst climate change induced extreme weather reduces our agricultural land's capacity to produce food. It is reasonable to accept that the UK will always have to import some food but imports are likely to become less reliable or affordable.
Saltford including the housing development area is approximately 5.5 km2, just over 2 square miles, or 1,400 acres. Taking account of the existing developed land within the housing development boundary (approx. 1.1 km2, or 270 acres), we have around 1,100 acres left.
If we assume approximately 1 acre of agricultural land is required to feed one person (this is affected by diet and food production methods) then Saltford's population of 4,073 (2011 census) requires 4,073 acres, i.e. a footprint some 3 times larger than Saltford and its green belt.
One of our Committee members, Phil Harding, wrote to B&NES Council on 30th January 2013 highlighting the need to protect our Green Belt agricultural land against unsuitable development. The letter referred to SEG's 'Six Core Principles' of why we cannot accept further development on our Green Belt, and asked:
- What plans B&NES Council has for producing a resilient food plan; and
- that B&NES Council will resist any attempts by central Government to impose housing numbers in the B&NES Core Strategy that would require development on Green Belt land that could be used for food production purposes (and wildlife habitat that in itself supports food production) should the future need arise.
You can download the text of the letter here:
In its reply to the 30.1.2013 letter, B&NES Council has said that a resilient food plan may form part of the strategic approach to local food and that sustainable development is central to the National Planning Policy Framework (NPPF).
SEG's response is that sustainable development, the purpose of the NPPF, by its very definition has to take a holistic approach. Food security and local food production is by implication a key aspect of land use planning. We feel that a resilient food plan should be part of B&NES's strategic approach to local, sustainable food.
The following two stage approach for taking the Core Strategy forward was suggested to B&NES Council by SEG on 18.2.2013:
- permit housing development on brown field sites (that have good access to public transport and places of employment only) in the short-medium term, and
- all green belt and agricultural land will be protected from housing or other development until and not before a green belt review and food resilience plan has been completed with full consultation.*
* subject to advice and detailed guidance from central Government on the UK's food resilience, future carrying capacity and the role that B&NES has within a national food strategy addressing sustainable food production that is secure, healthy and low carbon.
"Keeping land permanently open" is a purpose of Green Belt. Food is an "ecosystem service" in the National Planning Policy Framework (NPPF) whilst under 'Core Planning Principles' (17) the NPPF states that one common function of open land is food production.
The UK's Food Supply: Who feeds the UK?
If we consider the importance of green belt agricultural land for feeding the UK as a whole, we might question the wisdom and resilience of a proportional increase in our reliance on imported food in recent years to feed us. Is this sustainable in the face of increasing incidences of extreme weather events, due to climate change, and a rising world population?
The UK's overall self-sufficiency in food during World War II increased from a historic low of about one-third at the beginning to around two-thirds by the end. The UK's highest period of self-sufficiency during the 20th century was in the 1980s (60 - 70%). The UK's food self-sufficiency in food has declined since the 1980s. These official figures from Defra reveal the situation for recent years:-
1. ORIGINS OF FOOD CONSUMED IN UK : % OF IMPORTED FOOD
2. UK FOOD PRODUCTION TO SUPPLY RATIO (ALL FOOD)
- the "self-sufficiency" ratio - includes food exported that
could otherwise be consumed, feed, seeds and livestock
Based on the farm-gate value of unprocessed food in 2017, the UK supplied just under half (50%) of the food consumed in the UK. The leading foreign supplier of food consumed in the UK were countries from the EU (30%). Africa, Asia, North and South America each provided a 4% share of the food consumed in the UK.
The three largest value imported commodity groups (at 2017 prices) were fruit & vegetables, meat and beverages
Total UK cereal production has fluctuated, with significant dips in 2001, 2007, 2012 and 2013, linked to adverse weather conditions in those years. There was an 5% rise in 2017 compared to 2016 reflecting the above average yields recorded in 2015.
Successive spikes in the price of agricultural commodities since 2007 have led to higher retail food prices. They have not returned to the low price levels of pre-2007.
Low income households are affected disproportionately when food prices rise as they spend a greater proportion of their income on food.
Note. Source of UK food supply data is published as National Statistics from www.gov.uk: Food Statistics Pocketbook (annual publication, Defra)
RELEVANT FACTS THAT AFFECT OUR FOOD SECURITY
UK population in recent decades/years (Source: Census etc, rounded):
1901 = 38M; 1931 = 46M; 1941 = 48M; 1951 = 50M; 1971 = 56M; 1981 = 56M; 1991 = 58M; 2,001 = 59M; 2011 = 63M.
UK population density (approx):
674 per square mile. Land area of UK is 241,000 km2, 93,000 sq miles, or 60M acres* (approx).
The world's population is growing by 1.08% per annum which is 149 net additions every minute or 2.5 every second (2015 est.).
CIA World Factbook (2015)
It took until the early 1800s for the world population to reach one billion. Now we add a billion every 12-15 years.
United Nations (2017)
Agricultural land lost to land degradation (worldwide):
Estimated at 12M hectares* p.a. (23 hectares/minute!); enough to produce up to 20M tonnes of grain.
United Nations (2012)
Climate change will depress agricultural yields by 15-50% in most countries by 2050.
United Nations (2012)
*1 hectare = 2.47 acres. I acre = approx. 1 football/soccer pitch.
Links to sources of UK population and food security data/information:
- Population Matters (membership charity that addresses population size and environmental sustainability): www.populationmatters.org
- Global Food Security (Global Food Security programme from the Biotechnology and Biological Sciences Research Council, Swindon, UK): www.foodsecurity.ac.uk
Resources from SEG
You can download SEG's Food Security Information Sheet (2013) here:-
SEG's Gardenshare Document (tenancy agreement):
Want to grow local food in Saltford? Need help growing vegetables in your garden? Our tenancy agreement template is a useful document to help garden owners share their gardens with gardeners for mutual benefit and has been adapted for anyone in Saltford to use:
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A road bypass for Saltford?
The loss of Green Belt land from construction and the infill development that would inevitably follow, is just one of several reasons why a discussion paper produced for Saltford Environment Group's Committee says that at the present time the case has not been made for a bypass as a suitable solution for peak time traffic congestion in Saltford. The discussion paper looks at the potential
adverse effects our village might face if a bypass was to be built, creating more environmental, social and economic problems than it would solve.
The threat to our Green Belt and agricultural land from a bypass would be considerable as shown by the rejected proposals by B&NES Planners in January 2013 for a southern route bypass containing an infill of 5,000+ houses in the context of the draft Core Strategy. Furthermore the West of England Transport Study Final Report by Atkins (October 2017) concluded that a southern route bypass "would cross difficult terrain, with steep slopes south east of the village. It would be necessary to create a significant cut in the hillside, with a relatively steep gradient and potential requirement for a climbing lane in the westbound direction. These issues would collectively result in landscape impacts, major earthworks and relatively high scheme costs."
The policy discussion paper on a road bypass for Saltford (first published 9.1.13) is a 'living document' that we shall review and update periodically. It can be downloaded here:
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Policies and Government statements that protect (or help protect) the Green Belt/Environment
Saltford Placemaking Plan (2013) - from Saltford Parish Council
The following are extracts from Chapter 6 (Green Belt):-
- 6.1.4 The openness of Saltford's Green Belt also provides a sense of permanence to the countryside surrounding the village, provides separation whilst keeping in check urban sprawl from Keynsham, Bristol and Bath, and helps to safeguard the adjacent countryside including the Cotswold AONB from encroachment.
- 6.1.5 It is also a very important green infrastructure asset for Saltford and the wider community of Bath & North East Somerset. It provides ecosystems that support agriculture and wildlife together with an element of flood protection for the village from the river Avon and from surface water flooding arising from extreme rainfall events.
- 6.1.6 In addition to sports facilities offered by Saltford Golf Club and the sports ground by Saltford Hall, the Bristol and Bath Railway Path together with Saltford's extensive network of public footpaths provide the community and many visitors from neighbouring urban areas with a healthy environment much of which is considered locally to be of outstanding scenic value. This also enables leisure activities such as walking and cycling that are important for healthy lifestyles and a general sense of well-being.
- 6.1.7 93% of households that responded to the Saltford Parish Plan questionnaire in 2009 specifically said that they wanted Saltford's Green Belt to be protected. This clearly expressed view is reflected in the 2010 Saltford Parish Plan's objective to "prevent development that will encroach upon the Green Belt around Saltford".
The Saltford Placemaking Plan (2013) can be found on the SPC website from this link: Saltford Placemaking Plan.
The following planning policy documents provide policies at the B&NES area level on the Green Belt (they are undergoing revision to fit with the West of England Joint Spatial Plan):-
- B&NES Local Plan (2007)*: link to pdf.
*(most of this was superseded by the new Core Strategy on 10.7.2014. A new B&NES Local Plan is undergoing preparation in 2018-20.)
National Government Planning Policy (NPPF)
GOVERNMENT STATEMENTS ON (PROTECTING) THE GREEN BELT (most recent 1st):-
13.3.2019: Government to mandate net gains for biodiversity on new developments
In the Chancellor of the Exchequer Philip Hammond's Spring Statement to Parliament on 13 March 2019 the following statement was included:-
"The Budget 2018 set out how the government is accelerating the shift to a clean economy, building on the Industrial Strategy, Clean Growth Strategy, and 25 Year Environment Plan. The Spring Statement builds on this commitment: - to
ensure that wildlife isn't compromised in delivering necessary infrastructure and housing, the government will Mandate net gains for biodiversity on new developments in England to deliver an overall increase in biodiversity."
12.1.2019: "Don't build over the Green Belt to hit housing targets"
On 12th January 2019 during the BBC Radio 4 programme "Any Questions", the Communities Secretary the Rt Hon James Brokenshire MP said the following:-
"We want to see up to 300,000 homes built a year by the mid-2020s... I think that we can actually maximise the space, for example in places like our High Streets, actually ensuring that we're getting building over our shops where that's possible, seeing that we use some of the vacant spaces..."
In response to the question from Jonathan Dimbleby, the programme's Chairman, "Have you not in fact made it easier for developers to build on green field sites because of the alleged shortage that they claim there is, the planning laws have been eased have they not?" he replied, after making the point that the Government had created a plan led system where councils are able to set their local plans working with local communities:-
"On the Green Belt, absolutely that needs to be protected, that needs to be safeguarded. I am not one who is advocating that we should be, effectively, building all over our Green Belt in order to hit those housing targets. I think we can do this creatively, how we use the existing built environment and indeed brown field sites that are there, and actually the protections that are around Green Belt have been upheld and strengthened through our planning guidance to ensure that is the focus."
3.12.2018: ultimate decision is for the local planning authority
Replying to letter sent by Chair of Saltford Parish Council's Planning Committee (& Chair of SEG) Phil Harding to the Ministry of Housing, Communities and Local Government via NE Somerset MP Jacob Rees-Mogg concerning the role of developers and the decision making process for where new housing should be located, Jake Berry MP, the Minister for Local Growth at MHCLG made the following statement in his reply of 3rd December 2018:-
"Allocation of land for development will ultimately be made by the local planning authority, following public consultation on the options available. The technical assessment provides information on the range of sites which are available to meet need, but it is for the local planning authority to determine which of those sites are the most suitable to meet those needs."
24.7.2018: launch of the revised NPPF (2018)
Extract from announcement of new NPPF (2018) by The Rt Hon James Brokenshire MP, Secretary of State at the Ministry of Housing, Communities & Local Government.
Whilst giving councils real flexibility to make the most of their existing brownfield land, the revised framework makes sure they exhaust all other reasonable options for development before looking to alter a Green Belt boundary.
The government has more explicitly outlined the protection of the Green Belt in England, explaining the high expectations and considerable evidence that would be needed to alter any boundary.
11.1.2018: 25 Year Environment Plan (HMG) "A Green Future: Our 25 Year Plan to Improve the Environment"
Page 25, para.2. (Housing and planning): About 12% of land in the United Kingdom is designated as Green Belt land, and we remain committed to protecting it. The Green Belt plays an important role in preventing urban sprawl through the planning process.
11.1.2018: Principle of 'net environmental gain' from PM Theresa May
In her speech on the environment on 11 January 2018 (available at this link to gov.uk, Prime Minister Theresa May said:
"In the United Kingdom, we are blessed with an abundance and variety of landscapes and habitats. These natural assets are of immense value. Our countryside and coastal waters are the means by which we sustain our existence in these islands."
"The natural environment is around us wherever we are, and getting closer to it is good for our physical and mental health and our emotional and spiritual wellbeing."
"To make more land available for the homes our country needs, while at the same time creating new habitats for wildlife, we will embed the principle of 'net environmental gain' for development, including housing and infrastructure."
13.10.2015: "Thousands more homes to be developed in planning shake up"
(New measures that will make it easier to turn underused office buildings into new homes)
Available at: https://www.gov.uk/government/news/thousands-more-homes-to-be-developed-in-planning-shake-up.
"We're determined that, both in Whitehall and in town halls, everything is done to get the homes we need built."
"Today's measures will mean we can tap into the potential of underused buildings to offer new homes for first-time buyers and families long into the future, breathing new life into neighbourhoods and at the same time protecting our precious green belt."
16.10.2014: New rules announced by Communities Secretary Eric Pickles further strengthen green belt protections
Available at: https://www.gov.uk/government/news/new-rules-further-strengthen-green-belt-protections.
Communities Secretary Eric Pickles said:
"I am crystal clear that the green belt must be protected from development, so it can continue to offer a strong defence against urban sprawl.
Today's new rules strengthen these protections further, and ensure that whether it's new homes, business premises or anything else, developers first look for suitable sites on brownfield land."
4.10.2014 announcement by Communities Secretary Eric Pickles and Housing and Planning Minister Brandon Lewis
Available at: https://www.gov.uk/government/news/councils-must-protect-our-precious-green-belt-land.
Do housing and economic needs override constraints on the use of land, such as green belt?
The National Planning Policy Framework should be read as a whole: need alone is not the only factor to be considered when drawing up a Local Plan.
The Framework is clear that local planning authorities should, through their Local Plans, meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole, or specific policies in the Framework indicate development should be restricted. Such policies include those relating to sites protected under the Birds and Habitats Directives, and/or designated as sites of special scientific interest; land designated as green belt, local
green space, an area of outstanding natural beauty, heritage coast or within a national park or the Broads; designated heritage assets; and locations at risk of flooding or coastal erosion.
The Framework makes clear that, once established, green belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.
Do local planning authorities have to meet in full housing needs identified in needs assessments?
Local authorities should prepare a Strategic Housing Market Assessment to assess their full housing needs.
However, assessing need is just the first stage in developing a Local Plan. Once need has been assessed, the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, and in so doing take account of any constraints such as green belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need.
3.3.2014: statement on Green Belt revisions in local plans by Planning Minister Nick Boles
In a letter dated 3.3.2014 from Planning Minister Nick Boles to Sir Michael Pitt, Chief Executive of the Planning Inspectorate, the Minister made it clear that Local Plan Inspectors should not include the Green Belt unless there are "exceptional circumstances" (in line with the NPPF) and that when changing Green Belt boundaries it should "always be transparently clear that it is the local authority itself which has chosen that path". Furthermore, "the Secretary of State
will consider exercising his statutory powers of intervention in Local Plans before they are adopted where a planning inspector has recommended a Green Belt review that is not supported by the local planning authority."
The letter can be downloaded from gov.uk here: 140303 Letter (pdf on external website). Subsequent correspondence between Nick Boles and Sir Michael Pitt where Nick Boles confirmed (13.3.2014) that Inspectors should continue to determine whether Local Planning Authorities have followed the NPPF in seeking to meet the objectively assessed development needs of their area can be found from this external link:
17.1.2014 Local Government Minister Brandon Lewis statement about the Green Belt.
In that statement he specifically said, in referring to a similar statement made on 1.7.2013, that he:
"noted the Secretary of State's policy position that unmet need, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the green belt and other harm to constitute the "very special circumstances" justifying inappropriate development in the green belt."
"The Secretary of State wishes to re-emphasise this policy point to both local planning authorities and planning inspectors as a material consideration in their planning decisions."
That statement can be found at https://www.gov.uk/government/speeches/green-belt.
HMG consultation on national planning policy, Dec 2015 - Feb 2016
In December 2015 the Government launched a consultation on some proposed changes to the National Planning Policy Framework (NPPF) primarily dealing with definitions of affordable housing, increasing residential density and development on brownfield land. SEG became aware of this on 19 Feb 2016 and submitted comments on the deadline, 22 Feb 2016.
There were two questions posed by Government of particular concern:
- "Should local communities have the opportunity to allocate sites for small scale Starter Home developments in their Green Belt through neighbourhood plans?" and
- "Should planning policy be amended to allow redevelopment of brownfield sites for starter homes through a more flexible approach to assessing the impact on openness?".
In addition to addressing those questions in our response we also answered
questions on a proposal to amend the definition of affordable housing in national planning policy to include a wider range of low cost homes, and the benefits of strengthening policy on development of brownfield land for housing.
To see comments submitted to DCLG by SEG, click here: SEG comments on NPPF consultation, 22 Feb 2016 (pdf opens in new window)
Green Belt fields by Manor Road - the subject of a failed
planning application from developers (2012-14).
Photograph © Phil Harding 2013.
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Saltford's High Street in autumn. Photograph © SEG.
1. Saltford Placemaking Plan
Saltford's Placemaking Plan was produced by a Working Group appointed by the Parish Council and published on the Parish Council website in December (2013). The community was consulted on its contents between 23 November and 6 December 2013.
The purpose of this plan is to complement the strategic planning framework provided in Bath & North East Somerset Council's Core Strategy. It provides an updated and refreshed planning policy framework for managing development in the Parish of Saltford. The plan breaks Saltford down into 7 distinct character zones: Green Belt, Conservation Area, housing settlements (north and south of the A4), river Avon frontage, A4 corridor and the two large satellite sites within the Green Belt.
The following is a short extract from the Green Belt character assessment (Chapter 6):
The Cotswold AONB ridge and the distinctive local landmark of Kelston Round Hill (also known as Kelston Tump) together with Saltford's Green Belt and the river Avon provides a rural setting for the village. Despite Saltford's proximity to the cities of Bath and Bristol and the neighbouring town of Keynsham, this landscape gives Saltford its own distinctive character complementing and preserving both the setting of Saltford's
Conservation Area with its historical buildings and the newer housing developments within the village.
The openness of Saltford's Green Belt also provides a sense of permanence to the countryside surrounding the village, provides separation whilst keeping in check urban sprawl from Keynsham, Bristol and Bath, and helps to safeguard the adjacent countryside including the Cotswold AONB from encroachment.
It is also a very important green infrastructure asset for Saltford and the wider community of Bath & North East Somerset. It provides ecosystems that support agriculture and wildlife together with an element of flood protection for the village from the river Avon and from surface water flooding arising from extreme rainfall events.
You can view the Saltford Placemaking Plan on the Saltford Parish Council website from this link: Saltford Placemaking Plan on SPC website.
2. B&NES Placemaking Plan
You can view the B&NES Placemaking Plan that was adopted in July 2017 on the B&NES Council website from this link: B&NES Placemaking Plan web page.
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B&NES Core Strategy (2014-2029) & Saltford's Green Belt
Note 1. B&NES Council is combining its Core Strategy & the Placemaking Plan into a New Local Plan for the period 2016-2036 in line with the West of England Joint Spatial Plan (JSP).
Note 2. The Local Plan documentation is available on the B&NES website from this link: Local Plan 2016-2036
Note 3. The full Core Strategy documentation is available on the B&NES website from this link: Core Strategy (2014-2029)
At the Council Meeting on 10th July 2014 Councillors voted to adopt the Core Strategy. Saltford's Green Belt was NOT in the Core Strategy as land identified for development.
Whilst SEG welcomed this excellent news for Saltford's Green Belt, we naturally had concerns that other parcels of Green Belt land in the B&NES area would be developed including land East of Keynsham which would have a negative effect on the existing traffic congestion on the A4 and surrounding roads, quite apart from the unsustainability of developing such land.
The Core Strategy now forms part of the Development Plan for the District and will be used in the determination of all planning applications submitted to the Council alongside policies in the Joint Waste Core Strategy (2011) and those saved policies in the Local Plan (2007) not replaced by the Core Strategy.
The Core Strategy will be reviewed every 5 years however the first review will be timed to co-ordinate with the review of the West of England Core Strategies in around 2016. In terms of the 5 year housing land supply (plus a 20% buffer to provide for flexibility) that B&NES is required to identify, B&NES has stated the assumption that housing will start to be delivered on the sites removed from the Green Belt during 2017/18.
The Core Strategy document itself and other information and news concerning the Core Strategy can be found on the B&NES website from this link: www.bathnes.gov.uk/corestrategy.
Background to the Core Strategy (2014-2029)
NOTE: B&NES Council is combining its Core Strategy & the Placemaking Plan into a New Local Plan for the period 2016-2036 in line with the West of England Joint Spatial Plan (JSP).
The Core Strategy is the economic and planning strategy for this area's development over a 15 year period (to 2029) but will become part of the new Local Plan. Until it had been formally adopted on 10th July 2014 with the Government Inpsector's approval the Council had no planning policy framework against which housing applications could be judged, the Council was vulnerable to losing appeals on opportunistic and speculative planning applications, and the Council was denied access to vital sources of funding.
Delays were caused when the Government's Inspector agreed to suspend the public examination of the draft Core Strategy in July 2012 until summer 2013 since when examination hearings re-commenced and were completed in April 2014. This was due on a number of issues, including the area's housing needs and provision for the traveller community.
The July 2014 Core Strategy will be reviewed every 5 years although it is likely that the first review will be timed to coincide with a review of the West of England Core Strategies.
Implications for Saltford and our Green Belt: Saltford's Green Belt was not identified for development in the adopted Core Strategy (10.7.2014) so it should be protected by the planning system from development.
It is worth recording some of the key discussions and issues raised before the strategy was adopted:-
In response to local press reports that residents in Bath and NE Somerset were concerned over possible housing developments on the Green Belt in the forthcoming draft Core Strategy, SEG wrote to "The Week In" and this appeared in the 24.1.2013 edition; the text can be downloaded here: SEG letter to 'The Week In' on Green Belt development (pdf opens in new window).
As part of preparing the revised Core Strategy, B&NES Council Planning Officers put forward as an option the building of a bypass to the South of Saltford accompanied by 5,000 new homes. That option was not taken forward by B&NES Councillors.
At its monthly meeting on 5th March 2013, the Parish Council demonstrated the strength of feeling in the village by passing the motion "Saltford Parish Council notes that the bypass proposed was to become the housing development boundary for Saltford, and believes that the in-filling of 5000 additional homes in the existing green belt would have destroyed the village of Saltford as we know it. Saltford Parish
Council rejects this as an option completely both now and for the duration of this Council's term."
The Parish Council also voted to place on public record "its concern at the option of building a bypass around Saltford to be paid for by the building of 5000+ homes to contribute towards B&NES Core Strategy's housing numbers. It is difficult to see how such an option could be considered as sustainable development. This number of homes will nearly quadruple the size of Saltford and will be extremely detrimental
to Saltford's amenities and general character, destroying a large amount of Green Belt."
The strong stance taken by the Saltford community including SEG, the Parish Council and the Saltford Green Belt Campaign against Green Belt development in our area and in particular against the planning application to build up to 99 dwellings on Green Belt land south of Manor Road by Crest Nicholson (December 2012) has been key to keeping Saltford's Green Belt out of the Core Strategy.
The results of work on housing requirements and the availability of land for housing development were considered by B&NES Council on 4th March 2013. To quote from the paper on changes to housing requirement and housing land supply:-
"Development options to Saltford were considered in the SA [Sustainability Appraisal] analysis but are not considered deliverable in the Plan period."
Despite proposals from developers and landowners to develop Saltford's Green Belt, no housing development was proposed by B&NES Council for Saltford's Green Belt in the draft Core Strategy.
A series of engagement events for people to find out more and submit informed comments to B&NES Council to pass on to the Planning Inspector were held in March 2013. Prior to that consultation, SEG lobbied B&NES Council on the need to protect our Green Belt agricultural land against unsuitable development (see the item above on Food Security and the Green Belt: Who feeds Saltford?).
The Green Belt review report (April 2013) by Arup for the draft Core Strategy stated that for the Green Belt South of Saltford (including the fields south of Manor Road) "the Green Belt in this land parcel helps to preserve the identity and setting of the villages of Saltford and Corston."
SEG became aware on 5th December 2013 that the developers for the east of Keynsham Green Belt development, Mactaggart & Mickel Ltd, also wished to build on the Green Belt between Saltford and Keynsham, i.e. land directly adjacent to Grange Road and also surrounding Copse Road. The proposed development was not in the public consultation documentation launched on 23rd November 2013 for the east of Keynsham Green Belt development but an outline plan appeared on the B&NES Core Strategy website with other core
documents (link to outline plan - pdf opens in new window). It was part of Mactaggart & Mickel Ltd's master plan for development in this area.
The Strategic Housing Land Availability Assessment (SHLAA) Findings report (November 2013) from B&NES states that Mactaggart & Mickel "are promoting the whole of the Keynsham - Saltford gap to the South of the railway line. It is important to note that they are promoting not only the land to the west of the gas main, but also the land to the east i.e. a westward expansion of Saltford. To the north of the railway line (area b) a single land owner is promoting a mixed use housing, employment and marina development on an area described as the Broadmead peninsula."
SEG was naturally strongly opposed to this proposal. The Green Belt land at this location serves several purposes described in the National Planning Policy Framework (NPPF) as reasons for protecting the Green Belt from development, namely:
- to check the unrestricted sprawl of large built-up areas,
- to prevent neighbouring towns merging into one another,
- to assist in safeguarding the countryside from encroachment, and
- to encourage the recycling of derelict and other urban land.
SEG advised our Parish Council of this development and held discussions with its Planning Committee. We also contacted the Planning Department at B&NES. As this was not in the Core Strategy proposals from B&NES, B&NES was not supportive of this development and was NOT proposing the release of any land from the Green Belt on the Saltford side of the gap between Saltford and Keynsham. Furthermore, the Green Belt review report (April 2013) by Arup for the draft Core Strategy stated the following: "Also of importance is preventing the
merger of Keynsham and Saltford on the basis that these settlements are located between Bristol and Bath and the existing Green Belt gap between the two settlements is relatively narrow."
In our comments in response to the consultation on Green Belt boundary changes for the Core Strategy submitted by SEG to B&NES Council on 18 December 2013, we welcomed the (continued) protection of the Green Belt surrounding Saltford but asked the council to apply the principle of sustainable development that underpins the National Planning Policy Framework (NPPF) and to resist the imposition by central Government of additional housing numbers in the B&NES Core Strategy that would require Green Belt development. SEG said that any
development on the Green Belt over and above brownfield sites should be genuine sustainable development thereby benefiting the local and wider community.
On 7th March 2014, SEG's Chairman sent an email letter to B&NES Council saying that SEG were aware that during the March/April Core Strategy Examination Hearings developers and/or landowners were likely to attempt to seek the removal of Green Belt status from two or more areas of the Green Belt surrounding Saltford to allow development.
We referred the Council to key elements in the statement on 4.3.2014 by Secretary of State Eric Pickles in his refusal of planning permission for up to 99 dwellings on the Green Belt fields south of Manor Road (e.g. "inappropriate development in the Green Belt... a substantial sub-area of Green Belt identified as strongly serving the purpose of safeguarding the countryside from encroachment, and attributes considerable weight to this issue in the planning balance").
For the Green Belt land between Keynsham and Saltford (west of Grange Road), we highlighted the two very specific Green Belt purposes that land serves as described in the National Planning Policy Framework (NPPF), namely to "check the unrestricted sprawl of large built-up areas", i.e. Bristol and Bath, and "to prevent neighbouring towns merging into one another", i.e. Keynsham and the village of Saltford.
In its response (12.3.2014), B&NES Council said that Council officers would make as robust a case as possible regarding the soundness of the [existing proposed] Core Strategy at the Examination Hearings and would continue to set out why the proposed Core Strategy represents the most appropriate strategy for B&NES in light of the available evidence, in particular that relating to sustainability and Green Belt considerations.
There was a risk that the Inspector examining the Core Strategy, Simon Emerson, might ask B&NES to look again at proposals like this despite it being on the Green Belt and a development that would be contrary to Saltford's Placemaking Plan. However, as this would represent a change to the Core Strategy B&NES would have needed to consult on such a modification before it could be adopted in the Core Strategy.
The final report (dated 24.6.2014) from Simon Emerson, the Core Strategy Inspector, arising from the Core Strategy Examination Hearings held during March/April 2014 did NOT recommend inclusion of Saltford's Green Belt in the Core Strategy even 'though developers had sought inclusion of our Green Belt for housing development, something SEG and others had lobbied strongly against over a lengthy period.
Whilst he had agreed with the B&NES' proposals for modifications to the earlier draft Core Strategy to allocate four strategic sites for housing to be removed from the Green Belt at Odd Down, East Keynsham, South West Keynsham and Whitchurch and the removal from the Green Belt of additional land at East Keynsham as safeguarded land (i.e. for potential future development after the Core Strategy period), he did not recommend removal of land from the Green Belt at Weston, Bath, an
Area of Outstanding Natural Beauty (AONB) that cannot justify such a major development. The report concluded that the B&NES Core Strategy, as modified, provides an appropriate basis for the planning of the district and an increase in overall housing provision to around 13,000 dwellings.
Paragraph 110 of the report states:-
Accordingly, for villages such as Saltford, further development is permitted within the village, but the policy does not provide any support for expansion of the village into the Green Belt or for the Green Belt to be changed around such settlements. In the light of my overall conclusion that the Core Strategy can be made sound with various changes proposed by the Council, there are not the exceptional circumstances to justify changing Green Belt boundaries in this plan other than for the strategic allocations (in accordance
with my recommendations) or to signal that such changes are subsequently required as part of the Place-making Plan.
Receipt of the Inspector's Report represented the end of the Core Strategy Examination and therefore no further comments relating to the Core Strategy could be accepted by B&NES. The report was issued in readiness for discussion by the Full B&NES Council at its 10th July 2014 meeting when it voted to adopt the Core Strategy.