The South County Council Local Plan Consultation Document

Comments compiled by Peter D Box BSc., PhD.

1. Timing

It seems inappropriate that County Council is pursuing its own consultation so soon after the four county councils which constitute the West of conglomerate, namely , Bath and North East , and South Gloucestershire (SG), have carried out a single public consultation on their Joint Spatial Plan (JSP). A cynical observer may recall the Danish repetition of the Maastricht Treaty referendum in order to achieve the result the politicians required.

However, be that as it may, it seems even less appropriate that whilst the consultation is active organisations which would profit considerably should the Local Plan be adopted are permitted to market their particular proposals as if a decision had already been made.

2. Figures

The JSP was based on an unsubstantiated projection of housing requirements made circa 2014. Significantly this was before the UK referendum on membership of the European Union and hence while the UK was subject to EU laws on freedom of movement. Leaving the EU will, in all probability, lead to less immigration into the UK from EU countries and this could be reflected in a lower than projected housing requirement.

The JSP uses the Strategic Housing Market Assessment (SHMA) as a basis for its forecast to derive an Objectively Assessed Need (OAN) of 97,600 dwellings. The planned build of the JSP is for 105,500 units giving a contingency allowance of 8%. Of the JSP total, 32,500 units were allocated to SG but as the SHMA was prepared on a local council basis, the figure for SG is available, and gives a corresponding OAN of 24,000. The contingency allowance is therefore an eye-watering 35%. A fairer revision of the figures is called for.

3. Environmental Issues 3.1 Pollution

Like all local councils within the UK, SG has an obligation to meet specified reductions in CO2 emissions (Green-House Gases - GHG). At present the target reductions are framed in EU regulations but will almost certainly be transferred to UK regulations post Brexit. http://ec.europa.eu/environment/air/quality/standards.htm Any and all increases in commuting within the county will all but guarantee that these targets will not be met. It should be born in mind that housing schemes have been rejected on the grounds of predicted increases in air pollution. https://www.airqualitynews.com/2015/07/03/plan-for-97-sussex-homes-rejected-on-air-quality-grounds/ https://www.airqualitynews.com/2017/11/14/planning-decision-upheld-after-air-quality-ruling/

Pollution is not confined to the atmosphere: soil and water courses are also polluted within metres of even minor roads. Nitrogen dioxide (NO2), common in diesel exhaust, is particularly toxic as with water, it produces nitric acid. Other relevant forms of pollution include noise and the detritus which seems to accumulate in roadside verges and hedgerows: various forms of plastic are of particular concern because of their durability.

An effective way of controlling pollution is therefore to reduce commuting by locating housing developments as close as possible to places of employment.

3.2 Native flora and fauna

Many native species of flora and fauna are seriously threatened by the encroachment of urban areas into hitherto virgin countryside. Some are formally ranked as endangered. To protect these species with which we humans share our planet, every effort must be made to protect their habitats and allow unrestricted migration to ensure that gene pools are maintained in a healthy condition. Looking at that part of the JSP relevant to SG it is noted that three major housing developments are proposed for the northern area of the county. 500 units are planned for Thornbury (in addition to large housing developments in the pipeline), 1,200 for Charfield and a staggering 3,000 for Buckover. All three proposed developments are geographically close and whilst outside the current Green Belt (just) would effectively form an urban barrier between the Green Belt and open country to the north. Whilst some species adapt to survive life in urban areas, the long term effects of these adaptations is as yet unknown. When birds start to imitate telephone ring tones when calling for a mate, it is surely the start of a slippery slope to extinction.

Furthermore, I have yet to see evidence of a detailed survey of what native flora and fauna would be put at risk by these developments. The Buckover site mentioned above, is currently prime agricultural land: its implementation would destroy some five farms covering forty fields with 20km (12.5 miles) of field boundaries and hedgerows, all vital thoroughfares for wildlife. Also destroyed would be a disused quarry and an area of woodland (Rudge Wood); both habitats different to the prevailing farmland. Admittedly one version of a plan for Buckover shows the woodland retained within the development but surrounded by essentially urban development its unique character would be destroyed. Unless it were to be rigorously maintained it would be in danger of being polluted by such detritus as shopping trolleys, empty beer cans and the seemingly inevitable plastic waste. And such maintenance itself, would impact on the security of the habitat.

3.3 Green Belt

The function of the Green Belt is stated in the following policy: "A Green Belt shall continue to surround and separate Bristol and Bath and will be kept open in order to: • check the unrestricted sprawl of the Bristol conurbation and Bath; • assist in safeguarding the surrounding countryside from encroachment; • prevent neighbouring towns from merging into one another; • preserve the setting and special character of villages, towns and historic cities; and • assist in urban regeneration."

As mentioned in Section 3.2 above, proposed developments at Thornbury, Charfield and Buckover will contravene a significant amount of the Green Belt policies.

To counter this argument with the statement that the proposed developments are outside the current Green Belt is a cynical misinterpretation of the whole principle of Green Belt. The developments are on the edge of the Green Belt and would in any case clearly fail to safeguard the surrounding countryside from urban encroachment. The connection between Green Belt and open countryside would be severed, turning the Green Belt into something akin to a land-locked lagoon with unpredictable effects on wildlife within.

4. Infrastructure

4.1 General

Developments of the sites proposed for Thornbury, Charfield and Buckover, require a significant amount of infra-structure to provide residents with the services that they would expect. These cover a very wide range of facilities: medical, police, fire and ambulance, schools and libraries, water and sewage treatments and systems, recycling and waste disposal, shops and supply and probably many more. All these would not only require a considerable financial resource to set up, particularly at Buckover which is virtually a greenfield site, but would all add considerably to increased traffic on the road network with resulting negative impact on congestion and pollution

4.2 Transport

Throughout the JSP continual reference is made to the MetroBus as a solution to transport problems. Some of the references are deliberately vague as, like Thornbury and Buckover, no plans currently exist for routes to service those sites. Even if the vaguely promised MetroBus routes were implemented, could they provide the transport capacity required?

Consider Buckover, the JSP proposes a new dormitory town of 3,000 dwellings. This means a population of 10-12,000 people of which some 6,000 would initially be adults. Of these at least 5,000 would be in need of employment. Currently there are virtually no jobs at Buckover (one public house and a medium sized garden centre) and as the nearest towns of Thornbury and Charfield are also scheduled to receive additional housing of 500 and 1,200 units respectively, there is little prospect of all the New Wave Buckoverians finding jobs locally.

Bristol, over 10 miles away, will be the obvious job centre attraction for say 40%, i.e. 2,000 jobs. MetroBus vehicles will have a passenger capacity no more than a standard double-decker bus, i.e. less than 70. To carry the Buckoverians to work in Bristol will therefore require a fleet of about 30 vehicles, and this will be increased by existing Thornbury commuters (to reduce existing car use) and further to meet the needs of new residents. That a fleet of around 50 vehicles (plus drivers) would be needed to cope with the demands of this one route alone, illustrates an important conclusion: MetroBus is NOT a mass transport system.

Commuters will therefore resort to the use of private cars, and even encouraging car-sharing, the result will be severely increased road congestion and consequent air, soil and water pollution through the Green Belt which the Council is obliged to protect.

5. Employment

The JSP document identified the three major urban site within the area as Bristol (pop. 617,280), Bath (pop. 94,782) and Weston super Mare (pop. 84,452). These three form a shallow isosceles triangle with an east-west base of about 50 kilometres (30 miles).

Considering the employment for the rising population of the area, the JSP identified several enterprise zones and business parks, all of which were sensibly within or adjacent to, the BrisBathWsM triangle: i.e. they were nowhere near the major developments proposed for Thornbury, Charfield and Buckover. Proceeding with these developments is therefore an unsound policy which should be abandoned forthwith.

6. Public Safety

The location of the Buckover development gives rise to considerable concern. The current configuration shows the estate straddling the A38, a major trunk road and the recognised relief road for the nearby M5 motorway. To deliberately choose this site seems grossly irresponsible. With the so-called 'village centre', with all the associated social centres, schools, shops, etc. right on the main road is courting disaster. It would be expected that residents would very soon be demanding a bypass to divert through traffic. The only feasible route for such a bypass would be through the narrow gap designated a 'green corridor' between Buckover and Thornbury, thereby reinforcing the urban barrier across the Green Belt.

7. Alternatives

7.1 A Flexible Approach

South Gloucestershire County Council, together with its partners in the West of England association, should freeze their plans for future housing so far distant in the future. After Brexit has been effected and time given for immigration patterns to stabilise, a new assessment of requirements should be made and revised plans made accordingly. To rush ahead now and grant planning permission for major developments which could not be reversed, would be totally irresponsible.

7.2 Urban Regeneration

One of the functions of the Green Belt policy is to assist urban regeneration. This obviously covers use of brownfield sites. Each council within the West of England region has created and does maintain a register of brown field sites. Figures from the latest records (end of 2017) reveal the following:

Bristol: 220 sites total area 102.9 ha minimum no. dwellings 6,642 BANES: 33 22.3 816 North Somerset : 62 82.4 3,132 South Gloucestershire: 73 316.1 5,433 Totals 388 523.7 16,014

It should be noted that the number of dwellings for each site is a minimum. Thus it is conceivable that, with a little imagination, the total number of housing units which could be constructed on brownfield sites may be well in excess of the already large number of over 16 thousand recorded.

In addition to registers of brownfield sites, registers are kept of unoccupied properties. Recently a figure of almost 3,000 within Gloucestershire and South Gloucestershire was published (Thornbury Gazette Thursday November 30 2017 page 8). The corresponding figure for the City of Bristol is over 1,300. Whilst figures for the other two councils are unknown, it is clear that there is, within the West of England, a significant pool of housing which could be brought into use.

7.3 Dispersal

Major expenses in terms of finance, infra-structure provision and loss of productive countryside are associated with large developments on virgin land. All could be reduced or even avoided entirely if smaller, manageable developments were dispersed around already serviced areas. These could be the brownfield sites mentioned above, or gaps and spaces as yet unused.

7.4 Green Belt Adjustment

Whilst not advocating ad hoc annexation of designated Green Belt land, there may well be a case for sacrificing some such land adjacent to existing urban areas providing the Green Belt is enlarged by a greater amount further out. For example, use of Green Belt land to the north east of Bristol may be acceptable if the Green Belt is extended northwards to include Thornbury, Buckover and Charfield and thence to meet the Cotswold ANOB. The area of Green Belt within SG fell from 71730 ha in 2014 to 71630 ha in 2017: it would be a good time to reverse that trend.