The West of England Nature Partnership
Response to the Joint Spatial Plan, Issues & Options Paper

Introduction: Please find the West of England Nature Partnership’s response to the Joint Spatial Plan (JSP) Issues & Options document. This response has been reviewed and agreed by our partners and stakeholders, and builds upon the previous documentation we have submitted during the JSP process, notably our response to the pre-commencement document, the Sustainability Appraisal and the work we undertook on ecosystem services. This response consists of three parts:

Ø  Part 1 Response to the consultation questions (page 1 – 4)

Ø  Part 2: WENP response to the five spatial scenarios (page 5 - 8)

Ø  Part 3: Delivering the ambition for the environment: mechanisms for success (page 9 - 13)

Part 1: Response to consultation questions

1.  Have the most appropriate critical spatial issues been identified in addressing housing and wellbeing; the economy; the environment; and transport?

We recognise that this document is a high level, strategic document that aims to address how development can be sustainably distributed across the sub-region. With this in mind, we felt that the most critical strategic issues have been identified. We would also be happy to provide further detail on how these issues might be addressed at a later stage in this process, through our partnership, working groups and links to the environmental sector.

2.  Is the above vision the most appropriate one for guiding development and growth in the West of England up to 2036? Are there any changes you would like to see to the vision?

The vision recognises that growth cannot purely be measured on economic growth alone, and considers the social and environmental factors need for growth to be sustainable. Our only comment would be that instead of just recognising the rich and diverse natural environment, could there be an ambition to ‘enhance’ it for future generations.

In addition to the vision, we are interested in how success is measured. The West of England Nature Partnership would be keen to support the development of environmental (and social) indicators and alternative metrics to measure success (on how the vision is being delivered) alongside Gross Value Added, which has many limitations as an indicator of the performance of the economy. Indeed, applying some of the approaches set out in part 3 are likely to reduce GVA in the short term, but will provide long term benefits to society and the economy.

3.  Are the above spatial objectives the most appropriate ones for guiding development and growth in the West of England up to 2036? Are there any changes or are there other objectives you would like to see?

It is good to see environment as a critical issue that needs addressing, and we welcome the addition of ecosystem services being recognised, given the fundamental benefits they provide to the economy and society. In terms of the environment section, we would recommend the following text amendments:

7.  Maintain and enhance the environmental quality and function, and the attractive character and identity of the WoE’s cities, towns and villages and countryside Haveby ensuring place making is at its heart with high quality design that positively responds to local context and heritage assets.

8.  Ensure and embeds the services provided by the environment are factored in when making decisions about into our patterns for of sustainable growth.

9.  Respond to the challenges of climate change through adaptation and mitigation to minimise future risks, such as and minimise flooding. risk

10.  Have place making at its heart with high quality design that positively responds to local context and heritage assets.

11.  Maximise the use of brownfield land & minimise the use of greenfield land.

Furthermore, we have suggested a number of high level, good practice principles that should be applied when making decisions about how development should be approached to ensure the environmental issues are adequately addressed when delivering growth. These principles are further explained in Part 3: Delivering the ambition for the environment: mechanisms for success (page 9 - 13)

4.  Are we planning for the right number of homes? Is there anything else we should take into consideration regarding the number of homes?

Although the overall number of homes is important, we feel it is of equal importance to consider the decisions made about where the houses are located; how they are approved (through planning); how they are built (during construction phase) and operated once completed (handover and operational phase). In order for development to be sustainable, factors such as housing density, provision of green space, deployment of on-site green infrastructure (such as green rooves, and sustainable urban drainage systems) and quality of design need to be considered alongside just the number of houses.

5.  What needs to happen to ensure the homes we need are built by 2036?

In our view, this is more likely to happen if the overall approach gives confidence that the increased number of houses does not occur in a manner that undermines the quality of place that so many in the West of England enjoy. There is a need, therefore, to make compensating improvements in the natural environment in acknowledgement of the impact of development on natural capital and the services it provides. As the LEP is well aware, we have developed the concept of the Natural Capital Trust with this in mind. We would urge the proper application of sustainability principles to ensure that the social and environmental considerations are considered as an integral part of the decision making around economy and transport.

6.  What needs to happen to ensure enough of the homes built are affordable?

Not applicable to the WENP, but we would suggest that the provision of good quality green space for health & wellbeing purposes is critical for all new homes built, regardless of whether affordable or not. This may help reduce existing health inequalities, some of which may be associated with lack of access to green space.

7.  Have we identified the right employment issues?

8.  Where should new employment land be located? When selecting where employment land is located, we would encourage a similar methodology to be applied as is for deciding where housing is located. Although the impacts may differ, we would still encourage the following to be considered: the implications employment land will have on the landscape, the impact development will have on the local flora and fauna; proximity to important ecological sites; how this development is being mitigated for and any transport impacts that will arise. It is worth noting here, that some of the Enterprise Areas are located in flood risk zones, notably Bath City Riverside and Severnside & Avonmouth Enterprise Zone. Here we would encourage investing in the natural environment to improve green and blue infrastructure provision to help reduce this risk, through upstream management, SuDS schemes or wetland creation. It is often the case that this investment will need to be made away from the development itself, such a project could be delivered through the Natural Capital Trust using a Payment for Ecosystem Service model (further detailed on page 13).

In addition to this, we would also encourage options for housing and employment to be built together where suitable, to include opportunities for new employment to recruit from local areas, thus reducing additional burdens on the transport network.

9.  Is our priority of building more homes in Bristol and our main towns appropriate and how can this approach be achieved?

Each of the approaches is likely to have positive and negative implications for the environment. Please see Part 2: WENP response to the five spatial scenarios (page 5 - 8) for a detailed analysis on the impact each of the approaches may have on the environment.

10.  Have all the reasonable strategic locations been identified? Are there any others we should consider?

We simply note that if any new strategic locations come forwards, the ecosystem services provided by the land identified should be taken into account when considering the suitability of each new location.

11.  Do you have comments on the suitability of any of the strategic locations?

The West of England Nature Partnership has supported the development of the JSP Issues & Options paper by providing additional environmental evidence through our ecosystem service assessment (Technical paper: Ecosystem Service Evidence Part 2). We would hope to see that the ecosystem services currently being provided in each of the strategic locations are considered and adequately taken into account in the design and delivery of development, to ensure these services continue to be delivered as far as possible. As noted previously, some compensatory approach to mitigating for any reduction in services delivered should be considered as part of the overall approach to development.

12.  In your opinion, do some strategic locations have advantages or disadvantages in terms of addressing the critical issues identified in Chapter 2? Yes, different options will be better or worse for the environment, this is further detailed in Part 2: WENP response to the five spatial scenarios (page 5 - 8).

13.  Which spatial scenario (or mix of scenarios) is likely to best deliver the plan’s objectives as set out on page 16? Each of the spatial scenarios has different implications for the natural environment, as detailed in Part 2: WENP response to the five spatial scenarios (page 5 – 8)

14.  If a new settlement is a solution, how big should it be and where would you suggest it could go?

Please see our response to spatial scenario #5 (pg 8) which outlines some of the advantages and disadvantages for creating new settlements from an environmental perspective. Any new settlement would provide an opportunity to implement a ‘Green Infrastructure Led Masterplan’ (as discussed in Part 3, page 12).

15.  What transport improvements or measures would be required to support the scenarios

We would always support the provision of safe, landscaped cycle paths and walkways to encourage cycling and walking, as well as a well-connected, accessible and affordable public transport system to reduce car use, and additional pressures being applied to accommodate car travel (new roads, car parks etc) (further detailed in Part B, spatial scenario #3, pg 7).

Part B: WENP response to the 5 Spatial Scenarios

Introduction: This response was written by the West of England Nature Partnership in response to the Issues & Options paper. It provides the environmental commentary and implications for the environment on the 5 spatial scenario options suggested. The ambition is that this commentary will be considered as key evidence when making decisions on the location, size and type of development.

SPATIAL SCANARIO #1. PROTECTION OF THE GREEN BELT

1.1 BACKGROUND: England’s fourteen Green Belts cover nearly 13% of England, and 60% of the population live within greenbelt boundaries. Nationally, the greenbelt only contains 8% of statutory designated sites, though a significantly higher proportion of locally protected sites and ancient woodland can be found within the Green Belt.

1.2 THE CASE FOR: We recognise the Green Belt as an important strategic spatial policy designation that surrounds Bristol and Bath, and the towns and villages of the surrounding areas. This feature is hugely important for the landscape value it provides and the ‘green setting’ that helps create the sense of place for both cities, and towns and villages at its periphery. Although not directly contained within one of the purposes for Green Belt designation, because of its extent, relative permanence, accessibility, and the restrictions placed on new built development, some undeveloped and previously developed parts of the Green Belt also perform important environmental, ecological and amenity functions. If the Green Belt is to be retained in its present extent and shape as part of the JSP process the value of these contributions should be better understood and a commitment given to its enhancement as an explicit part of the development ‘equation’ in focussing development elsewhere.

1.3 ALTHOUGH: The ecological quality of the Green Belt surrounding Bristol hasn’t been fully assessed and may be of low ecological value because of the land uses and intensive farming practices. Similarly, the current value of the environmental (ecosystems) services provided by the land within the Green Belt, and the potential to provide greater benefits, remain to be evaluated. The percentage of the Green Belt that is or could be made publically accessible is also unknown, parts of the Green Belt in private ownership currently provide little opportunity for access for those living near to it. The services the Green Belt is currently providing needs to be established, as does the potential for this value to be enhanced.

1.4 KEY IMPACTS: From an environmental perspective, development should occur where it will do the least damage. Protecting the Green Belt is likely to result in more development occurring on land outside of the Green Belt. It is worth noting that this land may be of greater ecological value if it is within an ecological network, supports biodiverse populations, or is providing an important ecosystem service. Indeed, many of the protected sites in the region are found outside of the Green Belt signalling its higher ecological value.