The Core Strategy is a planning document which sets out the long term vision for development across Bath and North East Somerset (B&NES) until 2026. It forms part of the Local Development Framework and superseded the original Local Plan (as originally published in 2007). As adopted in 2011, the Core Strategy sets out the general allocations for new housing, jobs and other strategic developments such as transport and energy infrastructure. As of 2018, B&NES was in the process of preparing a new Local Plan up until 2036, to accompany the Joint Spatial Plan for the West of England which would provide the overarching strategic planning context for the four West of England local authorities. Following the rejection of the Joint Spatial Plan at the end of 2019, B&NES withdrew from the Plan in early 2020. This has resulted in a rescheduling of previously intended amendments to the current Local Plan.
2018/2019 – Core Strategy Review
B&NES commenced an Issues and Options consultation in November 2017 to review the vision, priorities and strategy of the Local Plan, including a focus on strategic development locations and university issues (student housing). At the same time the JSP issued a consultation on the Publication Document. Bath Preservation Trust responded to these consultations which cover housing numbers and the associated spatial strategies, as follows:
- 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 properly to address the ‘duty to cooperate’ in relation to the spill-over of Bath’s housing and transport market area into West Wiltshire and Mendip.
As of January 2019, BPT responded in detail to the Local Plan Issues and Options Consultation which considered options relating to the establishment of new strategic policies and amend existing policies for the region. In particular, we were pleased to see proposed new policy options relating to housing and the restriction of purpose built student accommodation, but we were also astonished to see that B&NES’s proposed ‘Vision for the Future’ of the region did not include a reference to heritage, despite being of key economic, social, and cultural value to the current and future success of the district. We were concerned by the absence of a proposed vision for retail within the city, which was in decline, and we also felt the proposed policy relating to holiday accommodation was too weak and lacked clarity.
Read our full 2019 consultation response here.
We suggested a simple addition to the wording of the ‘Vision’ (added words underlined) as follows;
Bath and North East Somerset will be internationally renowned as a beautifully inventive, and entrepreneurial and forward looking place with a world class heritage, a strong social purpose and a spirit of wellbeing, where everyone is invited to think big – a ‘connected’ area ready to create an enduring legacy for future generations.
2009 – Core Strategy Spatial Options Consultation
In 2009, the Core Strategy Spatial Options Consultation was launched, to which BPT responded. Our key concerns were as follows:
- The two District-Wide Spatial Options would fail to achieve the Council’s stated objective of regenerating brownfield sites ahead of greenfield development. Both of these options would risk delivering the worst outcome for the District as a whole, with major new development taking place in the City ’s Green Belt while the River Corridor, the three MoD sites and other brownfield opportunities within the city remain blots on the landscape of the World Heritage Site. We therefore proposed an alternative Option 3 which would drive the regeneration of brownfield sites across the District and particularly within Bath, and would increase employment and housing in Midsomer Norton and Radstock thereby reducing the excessively high levels of commuting from these towns. Under this option, no planning applications for an urban extension to the City of Bath would be considered before 2018 at the earliest, and then only if it has been clearly demonstrated that the need for growth cannot be satisfied on brownfield sites within the city boundary. We emphasised that work on the options for an urban extension to Bath must cease, with the effort being transferred to developing clear visions for the MoD sites, the River Corridor and other brownfield locations within the city.
- The Council’s preferred option for protecting the setting of the World Heritage Site would fail to comply with the UNESCO operational guidelines on buffer zones, the UNESCO decision on July 2009 that the protection of the setting of Bath needs to be strengthened, and Planning Circular 07/09 on protection of World Heritage Sites. We therefore called on the Council to introduce an ‘intelligent’ buffer zone based on the landscape setting study which was published alongside the Core Strategy Options consultation document.
- We recognised the importance of responding to the challenges posed by climate change. We were concerned that the Options document focuses too much on renewable energy generation and not enough on reduction of energy use and conservation of energy. There continues to be a pressing need to develop clear policies and guidance on the adaptation of existing buildings and on the acceptability (or not) of microgeneration installations within the WHS and its environs. BPT was keen to work with the Council to develop these policies and guidance, drawing on the work done by English Heritage and other heritage organisations.
- The River Corridor offered huge opportunities to help meet Bath’s need for sustainable new commercial and residential development, but we were yet to see evidence that the constraints, including in particular the flood risk issues, had been fully understood. Confirmation should be obtained from the Environment Agency that the ambitions for the River Corridor would be realistic before the Core Strategy could be finalised, and mechanisms must be put in place to prevent premature development proposals coming forward for decision before the relevant planning policies are in place.
- The Core Strategy needed to recognise the continuing importance of tourism to the economic and cultural vitality of Bath. Greater diversification of the economy was important, but should not be at the expense of our existing strength as an internationally renowned tourist and cultural destination.
- The Council should have clarified the status in planning terms of the Core Policies identified in the consultation document. The list of Core Policies was considerably more extensive than the Development Plan Documents and Supplementary Planning Documents set out in the current Local Development Scheme. Developers must be in no doubt that compliance with core policies such as the Historic Environment Policy and the World Heritage Site Management Plan is mandatory. Conflicts between the strategic objectives needed to be resolved in a transparent and objective fashion by a weighted options appraisal where the weightings applied would take account of the special characteristics of different parts of the district.