This week BPT has submitted a response to the Local Plan Options consultation.

The Local Plan is fundamental to how the city and the wider district is shaped for the next twenty years. The Options consultation process is the third stage of nine in its preparation, with the ninth being adoption, which has a target date of November 2025. The Options consultation is key for the Local Authority in gathering feedback to help shape the Draft Plan and BPT have very much welcomed the opportunity to engage via our submission and through meetings with Council officers.

Through the valued contribution of advisors, trustees and staff, BPT have compiled a response which is supportive of the Local Authority’s ambitions for the city and district. BPT welcomes the evident commitment to the climate and ecological emergencies, the endeavour to build much needed homes, the recognition of shortfalls in economic growth, community parity, attainment and quality of life levels.  However, BPT cannot endorse aspects including harm to the Green Belt and the loss of valued community assets such as allotments. While BPT may not be wholly supportive of every aspect of the Options document, comments are given with the firm intention to help the Local Authority in taking forward a Local Plan that is suitably robust to deliver its aspirations for the benefit of all communities.

Given the multitude of elements that the Options document cover the key points raised by BPT are as follows:

• Spatial priorities for the Local Plan must ensure active and inclusive consultation
• Policies must ensure high quality design which sustains the special characteristics of the World Heritage Site (WHS) 
• Priority for affordable housing is strongly supported and requires a clear definition
• There are no demonstrated exceptional circumstances for housing on strategic sites in the green belt
• Placemaking policies for development sites must emphasise a requirement for more effective master planning and for landscape-led development

Spatial priorities for the Local Plan must ensure active and inclusive consultation

The Plan should say how it will respond to local needs through more effective, active and inclusive consultation, participation and engagement through plan making and planning, decision making, strategies and delivery plans. Importantly a demonstrated commitment or evidence of this has not been shown.

BPT believes that sustainable and healthy places must be responsive to the needs and priorities of the communities (the basic principles of Doughnut economics) that occupy them and therefore the Local Authority must prioritise effective engagement with all relevant parties. They should be climate resilient and adaptable to change, and places where individuals can achieve their optimum level of health and happiness/well-being without reducing the level of health and happiness/wellbeing of others.

Policies must ensure high quality design which sustains the special characteristics of the World Heritage Site (WHS) 

In general, BPT is broadly supportive of the policies; however, we encourage engagement with the provisions of the Levelling-Up and Regeneration Act 2023 in regard to the WHS, the need for development to make a positive contribution to the special characteristics of the historic environment and stressed the need for sufficient resources to bring forward and maintain associated guidance and Supplementary Planning Documents (SPDs). Recommendations that policies are revised to ensure that high quality design is a requirement of development proposals have also been made.

Priority for affordable housing is supported and requires a clear definition

We strongly support the spatial priority to provide affordable housing; however, we believe that a very clear definition of ‘affordable’ is needed.

There are no demonstrated exceptional circumstances for building houses on strategic sites in the green belt

From brief calculations, which would need input from the Local Authority in order to establish their accuracy, it appears that the total housing need for the city for the period 2022-42 is 3,475.

• The brownfield/non-green belt sites in the Housing and Economic Land Availability Assessment (HELAA) could bring forward residential development total 2,006 dwellings.
• The non-green belt/brownfield site Local Plan site allocations which haven’t yet been built total 1,220 (omitting duplications with HELAA and sites we know to have been developed).
• This gives a shortfall in housing of 249, which we believe can be addressed via windfall sites, the transfer of uses from Purpose Built Student Accommodation and in exceptional circumstances, if comprehensively justified, small green belt sites.

The consultation document seeks to ‘test’ the suitability of two sites, owned by the Duchy of Cornwall to the west of Bath.

The site to the south-east of Burnett is partially in the parish of Corston, the remainder in parishes beyond our remit. BPT proposes supporting the exploration of potential longer- term development here; however, not in in this Local Plan period and only if exceptional circumstance for the release of land from the green belt to meet need which cannot be met on brownfield land is demonstrated. Detailed research on the landscape and a radical improvement in public transport provision would be required.

As for the other West of Bath area, development here would not provide any substantial public benefit that would outweigh the substantial harm to the World Heritage Site (WHS) and that the release of land from the green belt is not justified, and no exceptional circumstances have been demonstrated.

We have also suggested a number of changes to placemaking policies for development sites, with a specific emphasis on the need for more effective master planning and landscape-led development. And changes to development management policies have been recommended. These will be reviewed further when we respond to the draft Plan.

You can read our full response in the context of the Options consultation document and current local plan policies here

And our submitted response is available here