South West RSS
Regional Spatial Strategy
BPT Opposes Even Higher Targets for the Number of Houses for Bath
The Secretary of State has now considered the Draft RSS along with all the representations previously submitted. The Proposed Changes were published in September 2008 and the Government is set to impose even higher targets for housing and growth in the region.
The Bath Preservation Trust believes that the draft RSS presents a massive threat to our city and that the revised targets for housing and employment growth are ill-conceived and not supported by the evidence. We recognise the need for growth in both housing and jobs, but the targets set in the RSS must be deliverable if the special character of the World Heritage City is to be properly protected.
The Bath Preservation Trust submitted a formal objection to the Government in late October 2008. Whilst we accept that there is a local need for more housing we are seriously concerned about the following issues:
X Urban extension in the Greenbelt. An urban extension should not be considered until all other options in existing urban areas have actually been developed. In particular, land in the Area of Outstanding Natural Beauty (AONB) must be inviolable.
X Greenfield development. The RSS is wrong to rule out a sequential approach, brownfield before greenfield, to development.
X Bath’s capacity to accommodate 6,000 new dwellings. 6,000 dwellings within the city will only be achieved if the three large MoD sites are made available for mixed-use redevelopment.
X Student Housing. New student accommodation should count against the RSS housing targets.
X Infrastructure. The draft RSS gives no clarity about the infrastructure which will be required to support the new jobs and housing. Infrastructure must precede new housing.
The Trusts submitted response to the secretary of states proposed changes can be viewed here.
Background
Following the publication of the Draft Regional Spatial Strategy in 2006 the Trust participated in an Examination in Public held in Exeter in 2007. The Trusts submitted response to the 2006 document can be downloaded here.
. The Panel’s report was published at the end of December 2007 and can be accessed via this link . In broad terms the Panel’s report endorsed the draft RSS.
The South West Regional Spatial Strategy (2007 position)
An Urban Extension = 1500 Houses in the Green Belt
The Draft South West Regional Spatial Strategy (RSS) has been prepared by the South West Regional Assembly (SWRA) to comply with new Government legislation. It is intended to replace the present Regional Planning Guidance and covers the area from Cheltenham in Gloucestershire to Poole in Dorset all the way through Somerset, Devon and Cornwall to the Scilly Isles.
The draft RSS was prepared in 2005/06 and sent out for Public Consultation in the summer of 2006 with a deadline of response of late August. The next step in the process is for an independent Panel to conduct an ‘Examination in Public’ (EiP) of the broad strategy issues contained within the Draft RSS. This starts on April 17th in Exeter and is due to run for about 9 weeks. The Bath Preservation Trust will get a hearing at the EiP; as the local Parish Councils will not be allowed a hearing, the Trust will represent the views of those Parish Councils, which are corporate members of the Trust. The Panel will then prepare a report which will be sent to the Secretary of State and will be made publicly available. The Minister will issue proposed changes to the Draft RSS with a reasoned statement of decisions. There will be an 8-week consultation period. The revised RSS will be issued in early 2008.
The Bath Preservation Trust, together with the four Parish Councils most directly affected, has prepared a detailed response for submission to the EiP. This will seek to protect the World Heritage City and its unique setting for future generations.
The RSS seeks to set out Strategic Development Plans for the whole of this huge and diverse region to enable Government targets to be met. Under this plan B&NES are expected to attract up to 20,000 jobs over the next 20 years and would have to accommodate an additional 15,000 homes as a result. In the Bath area this would require 6,000 housing units to be created in the city, largely in the Western Riverside redevelopment and, controversially, 1,500 homes in an ‘Urban Extension’ on the South West fringe of the city. It is clear that if the jobs do not materialise the extra homes will not be needed.
An ‘Urban Extension’ is a euphemism for expanding into the Green Belt in the Environs of Bath. This is contrary to all of the 5 major purposes of the Green Belt contained in the Government’s own definitive guide.
The Draft RSS suggests that the ‘Area of Search’ for such an extension would be between the A367 and the A39 South West of Bath, an area that whilst within the Green Belt is outside the Cotswold AONB. This area contains many attractive steep valleys and rolling countryside and little flat land suitable for housing. It is also clearly within the ‘Setting of the City of Bath’ which is so important to the city’s World Heritage status.
The Bath Preservation Trust raised strong objections to this proposal and concluded that because of Bath’s special status as a World Heritage City and the importance of its setting consideration of a suitable location for such a development would be irrelevant because the very idea was entirely inappropriate. Nevertheless B&NES Council agreed with the principle and it has remained in the final Draft now under consideration.
In a recent twist to this plan a Landowner in the Area of the Cotswold Plateau just to the East of the current ‘Area of Search’ proposed that, even though his land is contained within the AONB, it is flat and level and should be considered as a much better option. He feels that his land should be included in a larger ‘Area of search’. This proposal is supported by a substantial report from Planning and Landscape Consultants but much of the information contained in these documents is based on inaccurate information or ‘facts’ collected selectively with a commercial slant.
At two recent public meetings Gerry Curran, the Council’s Executive Member for Sustainability and the Environment, confirmed that B&NES Council is totally against any possibility of major development in the AONB and will do everything possible to resist such a plan.
The Landowners’ Representatives have been invited by the EiP Panel to attend two sessions during the EiP process but South Stoke Parish Council, who are the elected representatives of the Residents of the Parish, have not. This is despite formal representations having been made to the Panel and the consequent denial of Residents democratic rights.
The issues at stake here are of national as well as local importance. An AONB has equal planning status with a National Park and is therefore afforded the highest level of protection against major development on this scale by all Government planning policies. To allow an ‘Urban Extension’ at South Stoke, within the AONB and the Green Belt, would desecrate a beautiful ‘Cotswold’ style village and ruin an important part of the ‘Setting of the World Heritage City of Bath’. In addition it would signal to developers that Areas of Outstanding Natural Beauty were no longer to be considered inviolable.