National Planning Policy Framework Consultation

The government is “revising the National Planning Policy Framework in order to achieve sustainable growth in our planning system…. also seeking views on a series of wider policy proposals (NPPF) in relation to increasing planning fees, local plan intervention criteria and appropriate thresholds for certain Nationally Significant Infrastructure Projects”

Respond to the NPPF Consultation here

before 11:45pm on 24 September 2024

Consultation Overview, Qs, Annotated Document, Outcome of Proposed Revised Method XLS

BOB Draft

How will this affect local decision making, North Somerset land and our related food security, especially in relation to any devolution to a regional mayor via WECA ?

How will this affect North Somerset Council and local decision making, land use and our related food security, especially in relation to any devolution to a regional mayor via WECA? What is sustainable growth in relation to a decreasing UK population? Who will benefit from this growth, North Somerset residents or the ever expanding cities, such as Bristol?

North Somerset Council has delayed its Local Plan to consider its response to the NPPF consultation stating, “The new standard method is 23,805 dwellings in North Somerset over the next 15 years – that’s nearly 9,000 dwellings more than our current Local Plan target. This figure also doesn’t take into account the needs of our neighbours” (31JUL24)

NSC has stated that around 85% of land in North Somerset is at risk of flooding. Also, that enclosed farmland makes up 68% of all land in North Somerset (Climate Emergency Action Plan pg49). If NSC doesn’t protect farmland what will happen to it? Will NSC permit building the 24K houses, solar panel farms, etc. on farmland?

Residents have approached NSC on a number of occasions asking NSC to protect local farming and food security, including asking for a Food Security Emergency to be called.

On 15 Dec 14 local MP Liam Fox spoke out in parliament (skip to 21:58 mins) on behalf of North Somerset and the high extra housing development imposed by central government coming from the Bristol University court challenge wanting to build on Green Belt land. NSC was subsequently asked to increase indentified sites from 14,000 to 21,000 houses. Liam Fox MP said, ".. it must be made clear that greenfield development should come only as a last resort after all brownfield sites are exhausted (See letter from DCLG relating to the Dec 2017 Brownfield Register). Finally, the infrastructure that is needed to support new development, including schools, GP surgeries and, where appropriate, roads must be provided by the developers; the cost must not fall disproportionately on local council tax payers. (See related Blog on Weston General Hospital A&E night-time closures starting 4 Jul 17). In North Somerset we are facing an expensive fiasco that is undemocratic and producing unsustainable outcomes. We have been very patient, and our very competent council has been extremely co-operative. Now we need answers." 

Liam Fox MP also said, "We seem to be in a ridiculous position. The plan [NS Core Strategy] was put forward in 2011, agreed by the inspector and adopted in 2012, yet here we are at the end of 2014. If I am not mistaken, at the end of 2015, we will begin the planning period in which we will look at housing allocation through to 2036. It would be the height of absurdity if we were one of only four councils in the sub-region to be asked not only to look at our 2026 housing allocation, but to start the process all over again at the end of next year and look at the 2036 allocation. Surely this is a complete waste of public resources, as well as being utterly contrary to what my hon. Friend the Minister says is the Government’s aim, which is to encourage greater localism." (current allocation of 20,985 is only up until 2026 so NSC will be looking for more sites). The Minister of State, DCLG representative Brandon Lewis replied "My right hon. Friend is absolutely right that we want to encourage localism. That is why we want the decisions to be made locally ... I am happy to discuss this issue with my right hon. and hon. Friends in greater detail at an appropriate point and to write to them to outline the detail behind their queries" (Link to Hansard Transcript and further information.)

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See also:

• NSC Local Plan Consultation 2039 BOB Blog

NSC outlines the ambition to look towards the West of England as a devolution geography and explore the benefits of a mayoral deal under the existing model.

North Somerset Council state the government, "... advised that their devolution ambition is to devolve new powers over transport, skills, housing, planning and employment support with more regions to benefit from integrated settlements based on certain mayoral conditions" NSC appear to have pre-determined a preference for regional 'Mayoral' governance in its response in Appendix 1. How will a regional mayor affect local democracy? What powers will residents and NSC lose?

UPDATE 18SEP24: NSC Executive meeting outcome

 

Public Question (at 16mins) and NSC discussion (at 21mins)

Council Committee Financial Position/Budget Devolution Discussion (at 44mins-1hr26mins)

North Somerset Council, "... recognise the need to make the case for additional funding and powers for the whole of the West of England in order to underpin any expansion to include North Somerset" WECA region or North Somerset residents benefit first? "It is unclear what timelines will be forthcoming with the new devolution bill, but together with partners we would be mindful of planned electoral cycles"

Is North Somerset Council being pressured into this regional approach due to its £12million debt and government withdrawal of our public funds for local spending, including funds via WECA's Local Economic Partnership? [NB using a figure of £12million debt would leave NSC with no financial reserves!} Is it considering local democracy, governance and accountability? Will residents still be able to interact with key decision making or will this power be devolved to the metro mayor? How much rural land and food security will be sacrificed for continous urban 'growth' for the UK's continuing population 'decline'?

NB: According to Wiki there are currently only 11 Combined Authorities in the country see map. (PDF) So why are local authorities being pushed towards a mayoral model? Why can't fund flow directly to the unitary authority area? Listen to current NSC budget problems due to regional and national budget allocations. What will be the effect on parishes as NSC devolve services upwards to WECA and downwards to parishes? Will parished precept taxes rise and be added back to the council tax bill? (What are parish precepts?)

Homes England review recommends offloading...  building safety Greater Transparency is required -  Homes England is an officer to WECA - see Companies House officers below? - What will be the relationship between WECA  and North Somerset Council with regards local priorities, expenditure, home building, future responsibilities and liabilities? Examples

• Grenfell Tower is in the Borough of Kensington & Chelsea (local decision makers) and also in the Greater London Authority (regional/mayoral decision makers), who was responsible for what aspects of this commissioning, payment, safety, signoff, etc.? (15SEP24)
• Homes England is set to receive just 0.1 per cent of the £69m it is owed by Ilke Homes, after the firm’s administration process was hit by equipment theft and problems selling completed modules... There is always an inherent risk when investing in new technologies with new business models that look to do things differently, but we remain committed to encouraging greater use of MMC [Modern Methods of Construction], supporting its growth, and diversifying the housing market.” (24OCT23)

Item 6 on the NSC Exec meeting agenda states, "North Somerset Council's response to Government's invitation around devolution (Pages 17 - 22) "

Report of Councillor Bell (Leader of NSC)

• Para 10. "Options Considered We have the option to respond declining the government’s invitation for exploratory conversations, which is felt unviable given North Somerset’s financial context and ambition." How will its 'ambition' affect local taxes and decision making?
• "Alternative geographies have been considered, however the West of England is North Somerset’s primary Functional Economic Area and is therefore being explored as our preferred option. We do not rule out alternative options in the event this becomes undeliverable."
• "The benefits of a mayoral versus non mayoral model will be explored through dialogue with government." What about the dis-benefits of having a mayor? What powers will local people lose?

• Para 2.1 "The Government have established a Council of Nations and Regions to bring together the Prime Minister, the leaders of the devolved administrations and metro Mayors to drive growth" How will governance and work with local democracy? How will decisions be made for NSC residents benefit, not only 'the greater good'? How will our land and food security be managed and protected?
• The government “... will not force places to take on a metro Mayor" If NSC join WECA do residents have to have a mayor by default?
• Para 2.1 "The council understands that Combined Authorities have been invited to share their ambitions for their places through a Growth Plan and that the West of England Combined Authority’s response will be published at their next committee meeting 20th September 2024".Surely this should say 'our' not 'their' places? What is North Somerset's need as opposed to Bristol, South Glos and BANES needs?

Things to consider:

• Populations are different in the four regions
  • approx Bristol 483K (42%), South Glos 263K (23%), North Somerset 203K (18%) & 196K (17%) - will any vote/referendum, if offered, skew outcomes? especially if areas vote together. What will happen to NSC land and food security?
• BBC 2016 NSC vote against West 'Metro Mayor' plan during government £1bn devolution plan.
  • " Mr Ashton also said any future "resources or powers" would be controlled autonomously by the proposed mayor leaving the local authorities "with no say in it whatsoever".
  • "We have worked hard with our fellow West of England partners to get the best available deal for the area, but too much remains that we are not prepared to support". He said the money offered would have to be borrowed, with around £400m spent on interest rates. (17JUN16)C
• Current NSC Leader, Mike Bell, stated in the Draft Corporate Plan (pg7) (now removed from its final  consultation version)
  • "Weston-super-Mare – our largest town is set to become the second biggest settlement in the West of England over the next decade." At the 4 October public meeting Cllr Mike Bell, confirmed that this would be second to Bristol!  
• The current NPPF Consultation Q19c states
  • "c. Maximising delivery in urban areas: the new formula increases targets by more than 30% across our Mayoral Combined Authorities, relative to the existing standard method. This better aligns with the ambition of our local leaders, and[footnote 5] will maximise agglomeration benefits by increasing the contribution new housing makes to economic growth. This approach will also make the most of our transport hu bs, support the objectives of brownfield-first and gently densifying urban areas, including building upwards where appropriate."
• Weston Mercury (12SEP24)
  • "The West of England Combined Authority (WECA) was created in 2017. It takes charge of some large strategic areas such as transport and is run by an elected metro mayor , currently Dan Norris" (15SEP24)
  • Ms Rayner said: “While we will not force places to take on a metro mayor, we will not shy away from making the case for their huge advantages, with some powers continuing to be reserved for institutions with directly elected leaders, such as mayoral combined authorities.”
• The Guardian England’s metro mayors make a farce of local democracy. They must be scrapped
  • "Towns and cities should have properly elected mayors, as is common in other democracies"
• First steps towards global governance and control via C40 Cities?
  • "C40 is a global network of nearly 100 mayors of the world’s leading cities that are united in action... Is this 'action' in local residents benefit or global governance and controlled decsion making?
  • Our Leadership Standards set the minimum requirements for all member cities and safeguard the integrity of C40 as a network of climate leaders. Membership operates on performance-based requirements, not on fees, and every city in the C40 network is reviewed annually against our Leadership Standards."
  • NSC is a member of the UK100 Countryside Climate Network. This is directly linked to C40 City Mayors via 2020 report pg7&15). Where do NSC intend to build new housing - on farmland or brownfield sites )? How is NSC managing any woodland or tree projects in relation to agriculture and food security needs?
• Wales
  • Wiki states, "Although Wales is included in the legislation, only one Welsh authority, Ceredigion, held a referendum on such a proposal, in May 2004. Over 70% of the voters voted against the proposal"

Dept for Levelling Up, Housing & Communities Letter 05MAR24

• "Ministers are concerned as to the West of England Combined Authority’s capacity to comply with its Best Value Duty" and issued a Notice "... following inconsistent action against concerns highlighted". The concerns we’ve identified include: " 
  • The poor state of professional relationships between the West of England Combined Authority Mayor and the representatives of the constituent members of the Authority which is impacting partnership working and potentially limiting the authority’s ability to optimise strategic opportunities.
  • The Authority’s constitution needs review and clarification to work in a more effective and agile way.
  • The function and purpose of the Authority has not been collectively understood and the roles, responsibilities and ‘powers’ of a combined authority are not fully grasped, resulting in confusion between strategic governance and day to day transactional activity.
  • The Authority lacks a clear, shared narrative regarding the West of England and how it will operate for the benefit of the wider region."
• "Whilst the Authority may continue to receive and be awarded government funding whilst under this Notice, we would emphasise that receipt of funding does not indicate the Department’s broader view of the performance of the Authority, nor would it indicate any change in the status of this Notice, with individual funding programmes being managed and assured independently by their respective departments. This Notice will remain in place for 12 months, after which time, should the Department deem it necessary to continue to seek assurance through such a Notice, the Notice will be reissued"

What is the ownership and governance of WECA? What are the voting powers of residents in this process? Which individuals are accountable to the public in the decision making, expenditure and outcomes?

Companies House West of England Combined Authority?

• One Appointment - 25MAR24 BRISTOL TEMPLE QUARTER LLP (OC451571) 70 Redcliff Street, Bristol, United Kingdom, BS1 6AL
• Filing History
  • Incorporation on 25MAR24 three weeks after Ministers concerns and letter above:
    • change of Relevant Legal Entitiy from The Homes and Communities Agency (Trading as Homes England) to Bristol Temple Quarter LLP 21AUG24,
    • Member's details change from The Homes and Communities Agency (Trading as Homes England) to Bristol Temple Quarter LLP21AUG24
• 3 People/Officers (15SEP24)
  • Bristol City Council
    • One Appointment 25MAR24 - City Hall, College Green, Bristol, England, BS1 5TR
    • BRISTOL TEMPLE QUARTER LLP (OC451571) (15SEP24)
  • THE HOMES AND COMMUNITIES AGENCY (TRADING AS HOMES ENGLAND)
    • One Appointment 25MAR24 - The Lumen, 2nd Floor, St James Boulevard, Newcastle Helix, Newcastle Upon Tyne, United Kingdom, NE4 5BZ
    • BRISTOL TEMPLE QUARTER LLP (OC451571) (15SEP24)
  • THE WEST OF ENGLAND COMBINED AUTHORITY (WECA)
    • One Appointment 25MAR24 - 70 Redcliff Street, Bristol, United Kingdom, BS1 6AL
    • BRISTOL TEMPLE QUARTER LLP (OC451571) (15SEP24)

WECA Structure, Ownership and Governance

• Who They Are
  • "The Combined Authority was set up in 2017 to make decisions and investments that benefit people living and working in Bath and North East Somerset, Bristol and South Gloucestershire. Together, our aim is to deliver economic growth for the region and address some of our challenges, such as productivity and skills, housing and transport." Although NSC is involved?
• Committee Structure (15SEP24)
  • "The Committee takes key decisions on matters affecting our region, including funding projects through the regional Investment Fund
  • ... chaired by the Metro Mayor, and is made up of the Leaders from our three constituent councils: Bath & North East Somerset Council, Bristol City Council and South Gloucestershire Council"
  • "The Chair of the West of England Local Enterprise Partnership (LEP) also attends committee meetings in a non-voting capacity"
  • " Overview & Scrutiny Committee: ... made up of 11 councillors drawn from across our three constituent councils. Its role is to review and scrutinise the work of the Combined Authority; it can also make reports or recommendations to the decision-taking committees. Three councillors from North Somerset Council are observers at these meetings and able to comment on matters that affect North Somerset."

If you see a footpath or public right of way that needs attention - report it to North Somerset Council

Bleadon has over 20 public rights of ways as maintained by North Somerset Council (NSC) and the associated landowners. If you think any need some work please contact NSC here.

Future plans for PROW can be found in the NSC Improvement Plan. These are the government stated NSC and Landowner responsibilities (07DEC15 & 04JAN24).

Purn Hill
Allotment
South Hill
Celtic Way
Roman Road
Shiplate Road

Bleadon Laybys have also received some attention:

West End
East End

Also the footpath entering the halls has been widened

Adjacent to village toilets

Resident asks North Somerset Council Executive to declare a Food Security Emergency

On the 17 July 2024 a resident addressed North Somerset Council Executive asking them to call a Food Security Emergency. This was based on the fact that, if the council has called a Climate and Nature Emergency, and food depends on both the climate and nature, then it follows that there will be a food security issue.

(NSC Video at 13:55 mins)

Related links:

	CO2Coalition website and Quiz
	Engaging Local Authorities Sustainable Food Places 2018 (PDF)
	Bridport Food Security Plan (PDF)
	New Sustainable Food & Farming Conference for the South West 22-23 November 2024 Bath & West Showground and Global Summit Version

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See also:

• Farmers Protection Dropped
• NSC Local Plan Consultation 2039

Your chance to support your rural community for generations to come

BOB's previous comments on a potential Rural Strategy (NIOV23)

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See also:

• NSC Local Plan Consultation 2039
  • Comments arising
• NSC Biodiversity Plan Consultation
• NSC Corporate Plan and Budget 2024-2028

Bleadon’s Annual Parish Meeting is this Monday, 29 April 2023, 7pm at Bleadon Village Hall

Previous minutes

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See also:

• See previous 2023 blog

The proposal is for the Gorge to be closed to vehicles initially once a month but MHNL state, “This is only the beginning…"

The Mendip Hills National Landscape Team (MHNL) has launched a public consultation to gather feedback, and invite you to share your feedback on the proposals via the survey here (Overview & Questions)

The consultation period will run from Wednesday 31st January to Tuesday 12th March 2024. This will help to shape the next steps agreed, so your feedback is important.

The proposal is for the Gorge to be closed to vehicles initially once a month. MHNL state, “This is only the beginning… We hope through the proposed ETROs we can improve the visitor experience and look forward to exploring more opportunities in the future.”

This follows feedback from local residents and businesses about the volume of traffic and anti-social driving in the Gorge, which could impact safety and people’s enjoyment of the area.” However, “...initial conversations with stakeholders, some businesses and organisations expressed concerns about the regulation impacting local businesses and car parking. Our proposed approach reflects these comments. The experimental order is intended to test an approach to understand how it could address the feedback received during previous discussions.

MHNL “want to create an experience that is fitting for a naturally beautiful and significant visitor attraction like Cheddar Gorge. … When the order is in place, Cliff Road (B3135) would be closed to vehicles from above the formal car parks to the Black Rock car park.”

This would allow walkers, cyclists and other visitors the chance to enjoy the Gorge more safely and enhance their visitor experience. For Cheddar an accessibility strategy was prepared setting out a range of short and longer term projects aimed at delivering sustainable transport improvements and enhanced accessibility.

See :

• Cheddar Gorge Public Realm Regeneration Project Report
• Appendix 1 Cheddar Levelling Up Fund Engagement Report
• Cheddar Accessibility Strategy

MHNL state, “It would offer opportunity for meet-ups, activities and events to be held in the Gorge and chance for everyone to enjoy one Britain’s most spectacular natural landmarks… Businesses throughout Cheddar remain open as usual during this time, as will the car parks at either end of the Gorge.

MHNL “will share any further updates on this website. You can also leave your email address in the feedback form to receive project updates.

For further information, you can contact the project team on CheddarGorge@distinctivecomms.co.uk or call 0330 107 0535.

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See also:

Bleadon Road and Bridge Road Closed -  'trial' one way diversion up Celtic Way

Bleadon Road will be closed from 08 Jan 24 -28 Jan 24 (Notice of Intent)

Bridge Road will be closed from 08 Jan 24 - 04 Mar 24 (Notice of Intent)

Updated road closures at https://one.network/uk/northsomerset (Search for Bleadon)

UPDATE 15JAN24 The road closure presentation was well attended, 80-100 people. Presentation here.

UPDATE 09JAN24 Following last night's council meeting (Min 373.9.2)  BPC call a residents meeting 15 January 2024 at the Bleadon Youth Club at 7pm

SOME BOB FEEDBACK

- school pickup/drop off, serious danger of children crossing the road

- we can discuss issues but will NSC listen?

- passing vehicles on narrow road, some maneuvers requiring large vehicles reversing up/down hill (collision concerns)

- traffic causing extra pedestrian issues as no footpath

- traffic signs at Queens Arms/Celtic Way/Shiplate Road junction forcing cars out into the middle of road in both directions (collision concerns)

- Celtic Way and Bleadon Hill grass verges being churned up

- potential damage to people's property at the edges of the narrow road

- Traffic speeding through Bleadon Hill and Celtic Way

- loss of businesses (incl Bridge Road, Jeff Brown petrol stations/shop services, Brent Farm) - clarity of one way needed

- timescales needed to be confirmed

- mid winter snow and dangerous icy conditions (slipping and gritting issues)

- there are weight restrictions, how can large vehicles go over the hill via Celtic Way and Totterdown Lane?

- traffic problems exaserbated by current road closures on Roman Road and Celtic Way

- increased traffic through the lanes in/out via Shiplate Road (incl from Cheddar/Axbridge direction up/down Celtic Way) 

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BOB received an email from a resident regarding the road closure and diversion up Celtic Way.

North Somerset Council states that it has "... carefully considered all alternatives and a one way system is to be trialled. Once the works are in progress we will continue to work with the developer to monitor how the traffic Management is working and will make adjustments if required."

As this is a trial residents should make any concerns known to North Somerset Council as soon as possible.

Temporary lights were installed in 2015 as indicated in BPC's newsletter at the time (BVN101, page 8).

The reasoning against installing traffic lights this time is described in BPC's 08 January Agenda (Min 373.9.2):

 

 

 

"2. Closure of Bridge Road

 

2.1 The works at the quarry necessitate the closure of Bridge Road for an extended period of time from 8th January 2024. The Parish Council was consulted about these requirements and indicated its expectation that temporary traffic lights would be installed at the Bleadon Road junction to enable traffic to safely enter and leave the village. The Council’s position was supported by Edenstone who included this requirement in the scheme submitted to North Somerset Council. The subsequent determination by North Somerset Council was that a more appropriate solution was to allow for access only through the Bleadon Road junction from the A370 and, as a consequence, to expect all traffic exiting the village areas to do so via Celtic Way.

 

2.2 It is evident that there has been a considerable amount of work to co-ordinate the required utilities work and minimise the requirements for further closures of Bridge Road. However, the use of Celtic Way – including for construction traffic – is considered inappropriate. There has been a significant amount of correspondence prior to and over the Christmas and New Year period to try and seek a better outcome than the one agreed by North Somerset Council. A number of Councillors have also met with representatives of Edesntone – who continue to support the Parish Council’s position. The two Ward Councillors have also been fully engaged and have registered their concerns regarding the appropriateness of the diversion. 2.3 A further update will be provided at the meeting"

 

This road closure is published on NSC website at https://one.network/uk/northsomerset (Search for Bleadon)

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WHERE IS ALL THE AGRICULTURE LAND GOING... GOING... GONE?

UPDATE 15JAN24: Local Plan 2039 Consultation presentation to 40-50 residents at the Youth Club

• Please support your rural community and post comments on NSC’s proposed Local Plan 2039
• Deadline 22 January 2024 - Consultation and associated documents here
• Especially Section 5 Countryside policy DP53 Best and most versatile land
• See all policies listed on pages 3-7, comment on any you feel passionate about
• NB: "The planning system entitles anyone to apply for permission to develop any plot of land, irrespective of ownership"

BOB'S COMMENT SUBMISSION

UPDATE 08JAN24:

Bleadon Parish Council (BPC) agree to host a resident meeting Monday 15 Jan 2024 Youth Club at 7pm, 

This meeting is a direct result of the comments made by residents at the Annual Parish (Resident's) Meeting in April 23. In May 23 BPC noted,

"Concern was raised about North Somerset Local Plan Policy in relation to solar panels and wind turbines on agricultural land and its impact on farming. Suggestion that a Parish Meeting is held for the next Local Plan Consultation for the Parish Councillors to hear residents’ views." (Min 364.10) The place and time for this meeting were finalised by BPC at their meeting on Monday (Min 373.5). (NB It is an official resident's meeting hosted/chaired by the parish council)

Please support your rural community and post comments on North Somerset Council’s (NSC) proposed Local Plan 2039 by 22 January 2024 here, especially Section 5 Countryside policy DP53 (See letter to Town & Parish Councils and presentation to NSC Executirve Committee)

NB: North Somerset Council state,

"At the close of this consultation period the council will summarise the main issues raised by the representations and submit that summary to the Secretary of State. If the representations raise matters which would suggest changes should be made to the Local Plan before the document is submitted the council will consider the appropriate way to proceed. The examination is expected to take place in summer 2024. This will be followed by the report of the inspector. If the document is found to be ‘sound’ by the inspector it is expected that the Local Plan will be adopted by the council in December 2024 at the earliest... The right to appear or be heard at the examination is limited to those persons who make representations seeking a change to the plan at this stage” (See Local Plan p2 & p10)

NSC Local Plan Guide (PDF) states that, “this consultation is a bit different to the previous three consultation stages in that the Government asks you to consider (Planning and Country Planning Act 2004 s20 as amended) whether the Local Plan policies are:

• Compliant - does the plan meet the legal requirements made under various statutes?
• Sound - has the plan been positively prepared, is it justified, effective, and consistent with national policy?
• Meet the Duty to Cooperate - has the council engaged and worked effectively with neighbouring authorities and statutory bodies? This means that specifically, we (NSC) are asking people to consider whether the policies and proposals in the Plan meet any of these tests when making a comment.”

NSC Current Interactive Local Plan Policies Map 

NB: Previous 'Renewable Search Areas' of Local Plan Solar and wind mapping has been removed?

Not all farmers are land owners. Those that are not landowners depend on their landlords to continually extend their leases, so that they can continue to farm. The actual land owners could live in the community, another part of the country, even abroad, using the land for investment purposes (e.g. in 2018 Bristol Airport was majority majority owned by Ontario Teachers’ Pension Plan Canada!) 

HOW IS NSC AND ITS POLICIES STRATEGICALLY ASSESSING AND PROTECTING FOOD PRODUCTION AND FOOD SECURITY IN NORTH SOMERSET?

• Why is farming, food production and food security NOT a NSC Corporate Plan priority or 'ambition'? (See  NSC Corporate Action Plan Land Use and related blog)

DEFRA Agriculture in the UK Evidence Pack September 2022 update (PDF)

• "20% of England’s sheep herd is in the South West
• 39% of England’s dairy herd is farmed in the South West.
• The West Midlands has the smallest average farm size compared to the average for England, closely followed by the South West [so if small farms are encouraged to diversify e.g. solar, BNG, nature recovery, housing, etc. food production and security will be affected]
• In 2020, after deductions for wages, rent, interest and asset depreciation and taking subsidy contributions into account, the total income from farming in England was £3.6bn, with the South West contributing the most (19%) and the North East the least (4%).
• Since 1988, the amount of food consumed in the UK of UK origin has fallen from 66% to 58% and the amount of food consumed of EU origin has risen from 18% to 23% over the same period. However, food of UK origin rose 4% and food from EU origin decreased 5% in 2021 compared to 2020.."
• Farming and environment evidence packs - latest editions

(p177) Policy DP43: housing (including rural exception schemes)

• "Developments will be expected to provide 38.5% affordable housing on greenfield sites and 20% on previously developed land.." How will food production land be protected?

NSC defintion "Sustainable development: Development which meets the needs of the present generation, without compromising the needs of future generations to meet their own needs." (Glossary) NSC policies need to protect the future of farming, food production and securtiy for future generations.

(Page 98) Local Plan Policy DP7 Large scale renewable and low carbon renewable energy

• NSC definition "Renewable energy: Energy generated from the sun, the wind, water and plant material (biomass)."
• "Proposals for energy generation from renewable and low carbon sources including wind turbines, solar photovoltaic arrays, biomass and hydropower (marine, river and tidal) schemes will be supported subject to no unacceptable impact on: (a variety of caveats including) ..."Infrastructure assets including power lines, roads, rail and aircraft safety."  Food is one of the government's 13 Critical Infrastructure Sectors, NSC's policies do not appear to reflect this status, however, "On greenfield sites, all proposals should seek to support continued agricultural use and biodiversity improvements"
• "Proposals for biomass/bioenergy developments will be approved provided they are of a scale and type which is appropriate to the location" "NSC definition "Bioenergy: Energy that is made from biomass or biofuel. Biomass: Organic material of biological origin (plant or animal), used as fuel to produce electricity of heat. This will include wood, energy crops or animal waste from farms." (Glossary) Biomass/Bioenergy production should not replace food production for people and animals.
• "North Somerset Wind Energy and Solar PV Supplementary Planning Documents will be updated to highlight potential locations identified as most technically suitable areas for renewable energy schemes from the Renewable Energy Resource Assessment Study (2021)." NSC Solar Photovoltaic (PV) Arrays SPD 2013 pg32 image pg34 image and Wind Turbines 2014.
• How are ethical and environmental issues to be addressed e.g. production (mining slave and child labour/health & safety, use of coal powered stations, etc.), shippping (carbon miles),  decommissioning (landfill & other environmental issues)
• Where are these updated documents published? Why are these important documents not updated and referenced during this consultation? Are these SupplementIary Planning Documents(SPD) the same as the published 'Landscape Sensitivity Assessment Solar PV and Wind Energy' Document? 
• NB Independent analysis of the carbon emissions associated with new nuclear plants have demonstrated they have smaller lifetime greenhouse gas footprint than that created by solar power and about the sam"e as wind power. It also operates 24/7, not just in the daytime or on sunny or windy days." (EDF and IPCC)

"The SPD will also provide guidance in relation to the Landscape Sensitivity Assessment (2021), which assessed the landscape sensitivity of different parts of North Somerset in relation to solar PV and wind turbine development."  Current version in consultation is Landscape Sensitivity Assessment Solar PV and wind energy development NOV 23, 

• C.67 "LCA G1 has a lower landscape sensitivity to solar PV developments as it has a greater sense of visual enclosure provided by the gently undulating landform and surrounding woodland and mature hedgerow boundaries."
• C.68 "LCA G2 has a slightly higher sensitivity to solar PV developments due to its more open character with low hedgerows, and the high frequency of seminatural habitats and historic features..." (pg 140)

"For some uses it may be possible to return the land to productive agricultural use without any loss of quality, should the proposed use no longer be required. For example, solar farms or similar. Suitable measures will be put in place to ensure this could be achieved." What suitable measures can be put in place? (See mega solar developments in Langford)

(p204)  NSC Local Plan DP53 Best & Most versatile land states,

• "The proportion of Grade 1 land in North Somerset is approximately 7% and 10% for Grade 2. 60% falls in Grade 3..." How much of this land is already in use as food production for people and animals, regardless of whether it is 3a or 3b, the latter seemingly a target for solar, housing, nature recovery, BNG, etc.? Note that the 3b land classification is said to be ‘moderate quality agriculture land’, not poor or useless, and has a role in current farming (See Langford Mega-Solar Development on grades 3b and 4 agriculture land) and mega-solar project maps on BOB. No mention of 3b or quantification of the area of land involved?

(p205) Local Plan DP54 Rural Workers Housing

• "Farmers are encouraged to diversify their activities and supplement their income from enterprises other than normal food production."
• What is being done to protect or 'offset' the land for the existing food production and food security? What is NSC doing to improve this locally?

(p91) Policy DP5 Climate change adaptation and resilience

• "Protect spaces for local food production and market gardening including allotments, tree planting, community orchards, community gardens and identify opportunities for community composting"
• "A Supplementary Planning Document (SPD) will be prepared to set out the detail for how these policy requirements will be implemented."
• Where is the detail of this document? Will it include protecting farming?

(p93) Local Plan DP6 Net Zero Construction READ THIS POLICY IN DETAIL

SEE GOVERNMENT ENERGY BILL - "...under this new legislation, those who fail to adhere to energy consumption regulations could face imprisonment for up to a year and fines of up to £15,000"

Good God! Is Britain really going to jail people who disagree with net zero?

• "... getting design right from the outset is much more cost effective than needing to retrofit later. The report recommends a space heating demand of 15-20kWh/m²/year by 2025 at the latest. ...guidance on meeting net zero recommends a maximum total energy use of 35 kWh/m²/year" What if you use more?
• "Renewable Energy Offsetting Residual energy demand should be met through the generation of onsite renewable energy, but if this is not technically feasible, the requirement may be met elsewhere by means of offsite renewable energy generation." What is NSC's expectations for old/ residential and non-residential buildings?
• "Renewable energy offsetting must only be used where it is demonstrated as not technically viable to meet the residual energy demands through onsite renewable energy generation. This is to ensure that new buildings are as energy efficient as possible and will not need retrofitting in the future. The council has a renewable energy offset scheme. Renewable energy credits will be purchased in order to achieve the net zero energy balance. This will be an agreed cost per kWp or per kWh generated, to meet the net annual energy demand for a scheme.The price per kWh generation shortfall will be agreed at planning application stage. An update to Creating Sustainable Buildings and Places Supplementary Planning Document will set out the process for securing offset credits, where these are required"
• "A building’s energy use is now considered to the best measure for net zero compliance, whilst reducing emissions on-site is no longer the best measure of sustainable design. Total energy use and space heating metric targets are considered to be the best mechanism to model and monitor net zero compliance because the electricity grid is decarbonising. One of the key advantages is that these metrics can be checked once the building is occupied without requiring further modelling or analysis."  
• Local Plan Glossary re:  Absolute Net Zero and Net Zero Operational energy and  Net zero whole life carbon building and Net zero embodied carbon building and  Net Zero Energy Standard: How will NSC treat old buildings with regards targets and offsets? How much of this 'off-site' renewable energy will use food production land?  

Carbon offsetting report – 'Carbon offsetting within an energy intensity policy framing Report to West of England Authorities Final' 30 June 2022

• "Prioritising rooftop solar would minimise the use of agricultural land for solar development and the associated landscape and other impacts. This is likely to align with understandable public and political opinion that we should prioritise rooftop installations ahead of greenfield solar."
• "... there are legitimate trade-offs between the use of roof-space for renewable energy generation to get to a net zero operational balance, and the use of limited roof space to meet policy requirements around climate adaptation, for instance for green roofs to provide habitat and mitigate overheating or the provision of roof gardens or amenity space for residents. This might mean that in inner urban areas where overheating is likely to be a greater concern, authorities place a greater emphasis on climate adaptation considerations and accept slightly greater use of off-site renewable energy to achieve a net zero operational balance." (30JUN22- updated 17NOV23)
• Does this mean NSC policies put greater emphasis on 'climate adaption' rather than on food production and security? Will inner urban areas, that have little/no open land, be looking to use rural NSC countryside to achieve their chosen net zero targets? How does NSC intend to protect agriculture and 'offset' food production and security?

(p18) Policy SP2: Climate change

• "The council declared a climate emergency in 2019 and has a target of being carbon neutral by 2030"
  • When were public given evidence to support this and when did the public vote on this NSC decision?

(p60) Policy LP9 Bristol Airport

• "More than two thirds of local authorities in the UK have declared their commitment to help delivering the Net Zero Transition through declaring a climate emergency."
  • Therefore one third have not - on what evidence did NSC declare one?

(p115) Policy DP15: Active and sustainable transport

• "Road transport greenhouse gas emissions represent a fifth of total UK emissions, the biggest contributor being private vehicle trips. The transport sector is, at 49%, the largest single source of carbon emissions in North Somerset. (not farming or emmissions from cows) This is considerably higher than the regional (South West) average of 24% and the national average of 24% from transport (Department for Business, Energy and Industrial Strategy, 2019). For the West of England region, transport CO2 emissions will rise by a further 22% by 2036 if we don’t act, increasing the risk of droughts, floods and extreme heat globally and in the South West.
• Current private vehicle trips and predicted growth represents a significant challenge in meeting national and local carbon reduction targets. It is not expected that mass take-up of low emission vehicles will solve the problem alone, nor will it solve the challenges of capacity, congestion, deteriorating health and well-being and pressure on space.
• One of the biggest challenges in reducing highway transport emissions is encouraging behaviour change."

(p121) Policy DP18: Travel plans

• support delivery of the North Somerset Active Travel Strategy and Climate Emergency Strategic Action Plan, encourage a greater proportion of trips by active travel modes, shape active travel neighbourhoods, reduce car travel and encourage sustainable travel, especially walking opportunities, for journeys less than one mile.

(p130) Policy DP22: Visitor attractions

• "Proposals must meet climate change objectives and have no adverse impact on environmentally sensitive areas such as the Mendip Hills AONB and areas at risk of flooding and minimise the development of permanent structures and hardstandings."

(p151) Policy DP34: Green infrastructure

• "The North Somerset Climate Emergency Strategic Action Plan identifies the need to replenish carbon stores in the district. GI is relevant since it involves providing and maintaining areas of vegetation and trees... The GIS objectives include ... the creation of bigger, better, more and joined-up woodland, grassland and wetland habitats to achieve the ambitions of the West of England Nature Recovery Network’"
• "Where it is not possible, practical or desirable for green infrastructure provision or enhancement to be made on site, then adequate measures for off-site provision will be made, which may involve formal agreements and financial contributions" How much of this off-site provision will be on food production land? How will NSC assess and offset food requirements?

(p154) Policy DP35: Nature conservation

• "Where a development requires off-site mitigation for greater horseshoe bats it is expected that developers will consider the use of the North Somerset Nature Parks strategic mitigation sites as a preferred means of achieving that mitigation. These Nature Parks are located in areas that have been modelled as providing the most important habitat and connectivity for bats and encompass a mixture of existing prime habitat for protection and areas that are suitable for enhancement". Does the modelling match real world outcomes? Will other districts also use NSC sites for offsetting their nature requirements (not only bats)? How will this effect farming, food production and security?

(p159) Policy DP36: Biodiversity net gain (BNG)

• "If it can be demonstrated that it is not possible to achieve the required BNG on site or that there are overriding benefits in making provision elsewhere, then off site mitigation may be acceptable. Where off-site mitigation is required, preference will normally be given to locations close to or well related to the development site" Has it been proven that developing on land (destroying nature in one are) and offseting it by using an off-site mitigation actually protects or improves nature? 
• "Natural England produced a Biodiversity Metric 4.0 in July 2021 for most developments, and a Small Sites Metric (SSM) for use on small development sites in some circumstances (such as where no priority habitat, protected species, or off-site mitigation is involved). These (or any subsequent versions) provide the methodology for the BNG calculation. The calculation and BNG assessment must be set out in the biodiversity gain plan, including data and maps showing habitats affected and proposed."
• "... this policy requires that developers should firstly aim to avoid, then minimise, then mitigate for, adverse impacts on biodiversity on site, before resorting to off-site mitigation... developers may be able to demonstrate that there are clear overriding benefits in providing supporting habitat for species away from the development (perhaps where species are sensitive to disturbance), in which case off-site mitigation may also be acceptable."
• See Bodiversity Net Gain Consulation blog

(p25) Policy SP6 Villages and rural areas

• "The policy approach allows rural buildings to be converted to dwellings, subject to criteria, as it makes use of an existing resource."  How does NSC policy ensure that barns needed for feed, housing animals and machinery, etc. are not lost?
• Where there are no existing suitable sites within settlement boundaries, a variety of non-residential proposals may be acceptable outside settlement boundaries." How will NSC policy ensure farming and variety of food production is not reducted?
• NSC definition "Rural building: All buildings outside of settlement boundaries other than permanent dwellings ... and buildings on existing or safeguarded employment sites, quarry or waste sites. Primarily this is likely to be agricultural building"

(p27) Policy SP7: Green Belt 

• "The Green Belt is regarded as a multifunctional asset which not only carries out the traditional purposes set out nationally by maintaining openness and protecting land from inappropriate developments, it also ensures productive farmland ..." Bleadon is not in a green belt area

(p31)SP9 Employment

• "Updated economic forecasts have been used to assess the requirements for employment land demand over the plan period (Employment Sites and Premises Requirements Evidence, Hardisty Jones Associates, 2023). This assessed economic forecasts across a range of sectors using data from Cambridge Econometrics and Oxford Economics. The assessment modelled the corresponding  demand for employment land and premises across the range of business land typologies in North Somerset and across the West of England." 81.25ha over WSM, Wolvershill, Clevedon and Portishead. Do the models reflect real world requirements? How much of this is greenfield food produciton land?

(p130) Policy DP22: Visitor attractions

• "Changes to farming policy and support payments are likely to result in an increasing number of farmers and landowners looking to diversify their businesses and potentially include visitor accommodation, camping and glamping" Will current or increased levels of food production be guaranteed or reduced? 

(p162) Policy DP37: Trees, woodlands and hedges

• "Proposals for off-site provision is made where tree planting is not appropriate or practical on site" Is food production to be used as tree off-site provistion? 

(p165) Policy DP38: Landscape

• "Where some harm to the local landscape character is unavoidable, but a development is otherwise deemed beneficial, then positive mitigation measures should be secured by a landscape condition or planning agreement involving works on or off-site as necessary."
• Will "rolling valley farmland" continue to be productive in a range of food produce (arable, sheep, cows, pigs, etc) especailly if landowners (not necessarily farmers) may be encouraged to diversify into solar panels (possibly with just sheep and no dairy produce) , wildflower meadows, trees/forestry, etc.?

(p208) Policy DP55 Agriculture and land based rural businesses

• Definition of "Land based rural business development: A business which requires a rural location and is totally dependent on the use of the surrounding countryside for its business success such as horticultural, equestrian development, farming" (Glossary p294) Not just food production
• "Planning permission will be granted for agricultural or forestry development on existing and new holdings, or development for the purposes of farm based and other land-based rural businesses or diversification provided that:" Will NSC guarantee that there will be no adverse effect on food production (for people and animals), e.g. wih the rise in planting trees?
• "Farm diversification activities can contribute to the local economy by providing opportunities for employment or recreation for residents and visitors and by resulting in increased patronage for local shops and services. Such activities, where they come within planning control, will generally be supported provided that the character and appearance of the countryside are not harmed." Will food production be 'harmed', character and appearance over necessary function of food production?

(p209) Policy DP56: Equestrian development

• "Permission for equestrian development will be permitted provided that either individually or cumulatively:.." a number of exeptions that do not include the protection of food production? Equestrian use removes land from food system category.

(p214) Policy DP58: Conversion or re-use of rural buildings

• "Retailing will not be permitted, other than farm shops, small scale village stores, proposals under 200m² or proposals that are ancillary to the main use.
• If the building was completed within 10 years of the application being submitted for an agricultural or equestrian use the applicant will need to demonstrate that the conversion of this building is essential for the long-term benefit of the associated agricultural/forestry/equestrian operation." How does this policy protect farms who rent rural building for the housing of animals, feed, machinery, etc.? How will this use be 'offset'?

(p218) Policy DP60: Employment on green field land in the countryside

• "Development proposals for new buildings for business use (Use Classes B2, B8 or E(g)) on previously undeveloped sites outside settlements will only be permitted where no suitable redevelopment sites or redundant rural buildings suitable for re-use are available and: • The proposal relates to processing locally grown produce or other land based rural business; However, how does this policy prevent the other caveats from reduces food production?

(p221) Policy DP62: Visitor accommodation in the countryside including camping and caravanning

• "The construction of new buildings for use as visitor accommodation outside the Green Belt and AONB will be permitted provided that: ...(conditions)
• Proposals for new or extended touring and static caravan sites outside the Green Belt and AONB will be permitted provided that:... (conditions)
• All visitor accommodation should: Not have a significant adverse effect on the living conditions of adjoining occupiers or adversely affect the operation of working farms;... (does this also include rotatied land use for crops and animals?)
• Proposals to use mobile homes on longstanding existing holiday parks for permanent residential accommodation will only be permitted if:
  • They are outside flood zone 3; and They are easily accessible in relation to existing facilities and services."
• How does this policy prevent 'caravan creep' and protect food prodcution?

NSC Strategic gaps Background Paper NOV23 (PDF)

"...., the relatively sensitive nature of the landscape, taking account of the topography and views, would suggest that if significant development was proposed there could well be a landscape reason for refusal." So how does this fit with potential solar panels over Bleadon fields? Does NSC's definition of development include business (caravan) and energy related development, or just housing?

SOME NSC Budget Info1 and Budget Info2 (06DEC23)

• • RURAL FINANCING 
  • REPF - Grants to Rural Business £106,229  in 2023/24 and £159,342 in 2024/25
  • REPF - Grants to Rural Communities £70,817 in 2023/24 and £106,229 in 2024/25 
  • Addition - Rural England Prosperity Fund - DP566 £177K in 2023/24 and £266K in 2024/25
    • How have rural communities accessed this funding, how has it been spent?
    • What has been allocated to Bleadon? REPF (17JAN24)
  • Decarbonisation of heat (boilers) £1.8 million  (Grants & Contributions)
  • Decarbonisation at Campus £1,197,000 (£886K Grants & Contributions + £311K Capital Receipts)
  • Eco Bus (library outreach vehicle (mobile replacement) £175K (Borrowing)
  • Office for Low Emission Vehicles (OLEV) £212,508 (Grants & Contributions)
  • Low Emission Vehicle Provision - Match (grant to be added once known) £45K Borrowing)
  • Purchase of Vehicles - Place (Electric vehicles?) £548,597 (£351,332 Borrowing + £123,266
  • Waste & Recycling - vehicles and electric vehicle top-up £12,352,595 (Borrowing)Reserves & Revenue + £74,000 Capital Receipts)
  • Environmental Services & Safer Communities - overspend of £1.423m
  • Purchase of Land to support biodiversity net gain £300K (Borrowing)
  • Land for Yatton Secondary £2 million (Grants & Contributions)
  • Land at Parklands Village £384,527 (Grants & Contributions)
  • Land Release Fund - Churchill Avenue, Clevedon £350K (Grants & Contributions)
  • Land Release Fund - Uplands, Nailsea £481,020 (Grants & Contributions)
•  
  • NSC faced "... a £50 million budget gap between now and 2028 - but since then, they've narrowed that to just £13 million. Just under £4 million of that ne eds to be found for the next financial year."
    • "At this time the council expects to receive £314.625m of grants and contributions from external stakeholders to fund specific schemes, which is the largest component of the programme, although the council will need to borrow £111.132m in order to be able to deliver all aspects of the programme." Budget Info2 

      CAPITAL PROGRAMME	BORROWING
      Adult Social Service	£0
      Childrens Services	£5,559,624
      Housing	£421,498
      Corporate Services	£13,491.998
      Place	£91,659,010
      TOTAL	£111,132,130

    • How much of this debt is attributed to NSC declared climate crisis, nature crisis and environmental related projects? 
    • How much  public land has NSC sold and for what purposes?In particular, how much smallholding land has been sold, and what effect has this had on farming? 
  • The total area of NSC smallholdings land as at 31 March 2022 amount to 166ha (410 acres). S See Langford solar developments.

(Video 17mins)

European Commission - Grazing for Carbon (10MAY17)

"The potential of grasslands as a sink for carbon is enormous in Europe"

What is NSC's plan for meat in the future, will local people rather than political party 'green' politics direct NSC decsion making? (See C40 Mayors Dietary Plan)

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See also:

• Short Guide to the pre-submission Local Plan 2039 (PDF)

• How to respond to the consultation (PDF)

• Related Biodiversity Plan Consultation (OCT23)
• Previous Local Plan Consultation (APR22)

and related info

• NSC Climage Emergency
• NSC Nature Emergency and Declaration (PDF)