I’m hesitant to criticise the West of England Joint Spatial plan.
It is a well written, produced and concise and the government at heavily promoting such joint strategic plans. It makes some tough choices and is to be commended for doint so. it is the first of a new breed.
However it does have the wiff of an updated Avon stricture plan. It has big 1960s planning advice group report style big blobs but without a clear indication of how these relate to transport infrastructure and settlement structure. There is also little indication of how it relates to the creation of a sustainable pattern of places and the kind of places that would be created – something all of the ‘classic’ strategic plans have, something for example the North Essex Garden Communities plan has in spades.
Part of the issue is it doesn’t really set out the strategic priorities of the plan. Which is a puzzle because that is required in the old NPPF and the only minimum requirement in the new draft NPPF.
For a city or cities surrounded by Green Belt the key issue will be how much development in the Green Belt and how much outside it. The plan has been criticised for allocating too much strategic development to road served development outside the Green Belt rather than locations closer to major areas of employment growth within it. This is exacerbated by the poor relationship between strategic development locations and the rail network.
The justification of the spatial strategy (in the JSP and startegy topic paper) is curious
Technical work and transport modelling have shown that it is not possible to sustainably accommodate all the identified growth needs entirely outside the Green Belt. The transport impacts cannot be fully mitigated even with substantial investment. Such a strategy would be dependent on some highly unsustainable locations that are very difficult and expensive to mitigate with only sub-optimal solutions….In response to concerns expressed through public consultation, the spatial strategy aims to minimise the impact on the Bristol and Bath Green Belt. However, due to the scale of provision required and the extensive nature of the Green Belt, the Plan does include some Strategic Development Locations currently with Green Belt designation as explained in the Spatial Strategy Topic paper.
Lets put this in plane English. It is saying we havn’t been able to put all of the development outside the Green Belt, but we have put as much as we can get away with without causing gridlock. the strategy rather than minimising length and number of car trips seems to be maximising them compared to alternative strategies requiring more Green belt loss.
There is the need to avoid the unsustainable expansion of the north and east fringes of the Bristol urban area beyond the substantial existing commitments that are identified to be delivered in adopted Local Plans.
So unsustainable they plan strategic locations 20 miles further out without rail access. Some of the development in the North Bristol area has been a distaste but it still has areas with significant potential for Smart Growth high density development within a 20 minute bus ride of Bristol which some of the (too small) ‘Garden Village’ proposals in the JSP don’t.
Ultimately the trade off between Green Belt and outside Green Belt is a political choice and one the NPPF allows to be made locally. I might not like the plan, an inspector might not like the plan, but I doubt they would reject the startegy for having made that trade off. Like so much post war planning it is as much sprawl as they can get away with.