HEARING STATEMENT Peter Brett Associates on behalf of IM Land Matter 2: Strategic Development Locations and Green Belt Exceptional Circumstances – Overarching Issues and the Relationship between the JSP and Local Plans (Polices 2 and 7.1-7.2) Introduction 1. This statement has been prepared by Peter Brett Associates, now part of Stantec (PBA), on behalf of IM Land (IM), regarding the soundness of the emerging West of England Joint Spatial Plan and specifically in response to questions relating to the SDLs and Green Belt exceptional circumstances. 2. IM agree that for sustainability reasons, exceptional circumstances exist to support some growth within the Green Belt, close to the urban locations of Bristol and Bath. 3. IM’s Regulation 19 representations explain in Section 3 and Appendix B, why the selection of the Banwell, Buckover and Churchill SDLs should not have been selected in preference to the alternative SDL at Pucklechurch West which is more consistent with the urban living focus and the infrastructure and jobs around the Bristol north east fringe. 4. IM recognises the JSP is a strategic plan and in accordance with paragraph 157 of the NPPF is proposing to illustrate broad strategic development locations; however, this makes it difficult to test the appropriateness of general areas. In redefining Green Belt boundaries, sometimes it is the defined boundary that determines appropriateness. 5. Infrastructure, particularly transport is an essential ingredient of sustainable development and the selection of SDLs. It is referenced in many parts of the Sustainability Appraisal (SA) process. A strategic plan which is unable to specify necessary strategic infrastructure, or which defers it to other documents is not a justified plan that provides a clear indication of how a decision maker should react (as per NPPF2012 para 154). 6. It is difficult to see how future Local Plans, which are being used as the mechanism for making the formal Green Belt changes can be made exempt for being considered against paragraphs 135-141 of NPPF2018 with regard to the SDLs. Question 2.1: The 12 strategic development locations and proposed amendments to the Green Belt will be considered in more detail in Matters 7.1 – 7.12. However, have the identified strategic development locations (SDLs) been selected in preference to possible alternatives on the basis of a robust, objective and consistent approach and is the 500- dwelling threshold for the SDLs appropriate? 7. No, IM has expressed concerns about the robustness of each stage of the SA process as part of earlier representations. Three pre-submission SAs have been prepared, in 2015, 2016, 2017 plus an addendum note in April 2018 followed by a Consolidated SA in November 2018 (WED009), which post-dates the submission of Regulation 19 representations in January 2018 and submission of the Publication Plan for Examination. 8. IM’s objections at Regulation 19 stage, about the way the SAs were prepared, remain unanswered in the addendum (SD9L) or the additional appendices which appear to sit alongside the earlier SAs. It also appears that the LPAs recognised the flaws with the SA process by the production of a post submission Consolidated SA (WED009), which appraises 3 new alternative development scenarios plus a re-appraisal of what it describes as the 5 original alternative development scenarios set out in SD9L. In all, WED009 re-writes and replaces what must now be accepted as flawed SAs that were used to guide the preparation of the Submission Draft JSP. 9. IM recognise that limited Main Modifications have now been published, but these do not change the underlying issue that some SDL locations are unsustainable and not consistent with National Policy or \\Pba.int\bri\Projects\40168 Land at North East Bristol\Technical\Planning\JSP\Hearing Information\Hearing Statements\Matter 2 - SDLs and Green Belt Exceptional Circumstances\20190524_Matter 2 - SDLs and GB Exceptional Circumstances.docx Page 1 of 12 HEARING STATEMENT represent an appropriate, let alone the most appropriate strategy when considered against reasonable alternatives. Its objections at Regulation 19 stage to the selection of Banwell, Buckover and Churchill remain unanswered. In response to question 2.1 the following summary is provided: Robustness 10. The fact that the WED009 (November 2018) is almost a full, post submission re-write of previous SAs demonstrates the WoE accept their original approach was not sufficiently robust. The issue is that the current SA did not guide the pre-submission plan making process. Objectiveness 11. In respect of land at Pucklechurch (omission site) the SA was not objective from the outset. It included land that is not part of IM’s proposals and did not fully explore the benefits of this location. Furthermore, it highlights some of the issues that the first 3 SAs raised in respect of Buckover, Banwell and Churchill. Section 3.2 of IM’s original Regulation 19 representations sets out the benefits of Pucklechurch West. By way of an example to demonstrate the shortcomings, IM’s vision document appended to this statement (Appendix 1) revisits the findings of the Consolidated SA and applies the criteria to the site (excluding wider land that formed part of the M4 to Shortwood site). 12. To further illustrate the point, extracts from the SA scores set out in document SD9G Appendix G is provided in Appendix 2 to show how Pucklechurch West performs more sustainably when compared with Banwell, Buckover and Churchill. 13. For a site which is more consistent with the urban living focus (being on the north eastern edge of Bristol), it is unclear why it was dismissed very early in the plan preparation process. Consistent 14. As set out in IM’s Matter 1 Hearing Statement (Q.1.4(c)) there are inconsistencies in the way the SA was used to assess potential SDLs. These are also set out in IM’s Regulation 19 representations (paras 2.4.43-2.4.55), with one such inconsistency being that potential SDL assessments are inaccurate and unjustified. 15. The SDLs of Banwell and Churchill are located a greater distance from the nearest urban centre with poorer sustainable transport connections to existing services and facilities than other locations yet have been scored better. For example, Banwell and Curchill SDLs scored higher for SA categories 2c (access to community facilities), 2d (access to education) and 2e (access to town centres) than West Pucklechurch. However, Banwell and Churchill are located approximately 8km and 11km from the centre of Weston-super-Mare respectively, whereas West Pucklechurch is approximately 2km from the new Emersons Green centre. 16. Furthermore, it was placed in the “dispersed” locational typology even as late as April 2018, despite being near to both Emersons Green centre and Emersons Green Enterprise Zone with good existing sustainable transport connections and opportunities for further improvements. 17. It is therefore not clear how the location assessments and scoring has been carried out consistently across all of the potential SDL sites. 18. With particular regard to the Green Belt assessment, the consultation document is clear that it is not possible to sustainably accommodate all the identified West of England growth needs entirely outside the Green Belt. Thus some development will need to take place within the Bristol and Bath Green Belt. In reviewing the JSP assessment methodology and summary, there are four overarching matters which indicate the process has not been undertaken in a robust and consistent manner: a) With regard to Green Belt Purpose 1, the authors have conflated ‘unrestricted sprawl’ issues with coalescence. This approach evidently does not correlate to Green Belt Purpose 1, nor the methods; and b) Conversely, with specific reference to cells 26b and 26c to the west of Pucklechurch, and with regard to Purpose 2, the authors have accepted that the land between Bristol and Pucklechurch does not contribute to the purpose of preventing the ‘merging’ of towns; c) In relation to the role of the landscape between Yate and Coalpit Heath SDLs, very little weight appears to have been given to the manner in which growth might be perceived from the adjoining landscape as part of a combined release where there could be up to a 50% reduction \\Pba.int\bri\Projects\40168 Land at North East Bristol\Technical\Planning\JSP\Hearing Information\Hearing Statements\Matter 2 - SDLs and Green Belt Exceptional Circumstances\20190524_Matter 2 - SDLs and GB Exceptional Circumstances.docx Page 2 of 12 HEARING STATEMENT in the ‘gap’ (in that case). The evidence base does not determine robust and defensible boundaries, it merely indicates aspirational green corridors to separate adjoining SDLs, yet this is a fundamental element of the functioning of the Green Belt and the prevention of unrestricted sprawl. d) In relation to cells 26b and 26c, the JSP assessment elevates the parcels’ role by attributing an in-combination role with the adjoining cell (26a - Pucklechurch Ridge), which does in fact provide a defensive boundary and separation from Bristol. These three parcels together are considered to perform a ‘major contribution’ to the Green Belt Purpose 1 which we would agree with. However, it is cell 26a that performs the most strongly in relation to Purpose 1 and if cells 26b and 26c are considered independently and they are considered not to make a major contribution to Purpose 1 in the same way. 19. PBA’s Regulation 19 representations (paras 2.4.31-2.4.41) expand on these concerns relating to the JSP’s Green Belt assessment. Question 2.2: In principle is it a justified and effective approach for the JSP to identify Strategic Development Locations (SDLs) in only broad and indicative terms and to leave to Local Plans the formal allocation of sites for the SDLS? 20.