NSC Local Plan Consultation 2039

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)