The West of England Joint Spatial Plan was a drafted plan that covered the local authorities of Bath and North East Somerset, Bristol, North Somerset and South Gloucestershire. The plan proposed a shared, cross-border collaboration to provide new housing and infrastructure across the West of England area, outlining an overall need for 105,000 new homes by 2036. In 2019, the Inspector advised that the plan was withdrawn on the grounds that fundamental aspects of the plan were not considered to be sound, and highlighted that alternatives to major new housing sites set out in the plan were not properly considered. The plan ultimately collapsed in 2019 when local authorities formally withdrew the plan, with the intention of delivering their own separate local plans.
2018 – Local Plan Options Consultation
BPT submitted comments to two important consultations for the Local Plan and Joint West of England Spatial Plan, which considered the housing numbers and associated spatial strategy for B&NES and the wider region. The B&NES review was an update of the existing Core Strategy and Placemaking Plan, reappraising housing needs and trajectories and with a particular emphasis on student housing. The JWE plan sought to find solutions to the very large housing need across the region, including an alarming current shortfall in affordable housing. The key messages BPT has put across were:
- Market-led student housing should not go on land suitable for other purposes and there should be control of the type of student hosing built so that it meets actual needs rather than reaching only for the richer overseas student market.
- Better ways of ensuring delivery of affordable housing should be found in order to resist calls for over provision of market housing and ever expanding use of greenfield/Green Belt land.
- The failure of both plans to properly address the ‘duty to cooperate’ in relation to the spill-over of Bath’s housing and transport market area into West Wilts and Mendip.
Read our full response here.
2008 – Proposed Changes to the RSS
The Secretary of State considered the Draft South-West Regional Spatial Strategy (RSS) along with all the representations previously submitted. The Proposed Changes were published in September 2008 and the Government was set to impose even higher targets for housing and growth in the region.
Bath Preservation Trust felt that the Draft RSS presented a massive threat to our city and that the revised targets for housing and employment growth were ill-conceived and not supported by the evidence. We recognised the need for growth in both housing and jobs, but the targets set in the RSS should be deliverable if the special character of the World Heritage City is to be properly protected.
Bath Preservation Trust submitted a formal objection to the Government in late October 2008. Whilst we accepted that there was (and continues to be) a local need for more housing, were seriously concerned about the following issues:
- Urban extension in the Green Belt. 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.
- Greenfield development. The RSS was wrong to rule out a sequential approach, brownfield before greenfield, to development.
- Bath’s capacity to accommodate 6,000 new dwellings. 6,000 dwellings within the city would only be achieved if the three large MOD sites were made available for mixed-use redevelopment.
- Student Housing. New student accommodation should count against the RSS housing targets.
- Infrastructure. The draft RSS gave no clarity about the infrastructure which would be required to support new jobs and housing. Infrastructure should precede new housing.
2006/2007 – Draft Regional Spatial Strategy & Public Examination
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. Under this plan, B&NES were expected to attract up to 20,000 jobs over the next 20 years and would have had to accommodate an additional 15,000 homes as a result. In the Bath area this would have required 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 (a euphemism for expanding into the Green Belt in the Environs of Bath). The Draft RSS suggested that the ‘Area of Search’ for such an extension would be between the A367 and the A39 South West of Bath, an area of many attractive steep valleys and rolling countryside, which remains critical to the setting of Bath and the city’s World Heritage status.
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 remained in the final Draft of the Strategy.
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 for an ‘Urban Extension’. He felt 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 was based on inaccurate information or ‘facts’ collected selectively with a commercial slant.
In its Final Draft, the Strategy was referred to an independent Panel to conduct an ‘Examination in Public’ (EiP) of the broad strategy issues contained within the Draft RSS. The hearing was held on 17th April in Exeter, which BPT attended on behalf of the Parish Councils, who were not permitted to attend.
The Panel’s report was published at the end of December 2007. In broad terms, the Panel’s report endorsed the draft RSS.