Business concerns about the WoE draft Joint Spatial Plan and Joint Transport Study
The four West of England councils are continuing to work to produce a Joint Spatial Plan and a Joint Transport Study which will be the blueprint for where new homes, employment, infrastructure and the required transport links are located, which can then be built over the next 20 years
Businesses and residents have until the 19th of December to respond to the current public consultation on these plans. We strongly urge you and your colleagues to put in a response which you can do here. And please encourage others to do so.
Business West Chambers & Initiative have a series of significant concerns with the current Joint Spatial Plan being proposed by the four West of England local authorities. Working with a group of our members we will be submitting a response. Below we set out a short summary of our five main areas of concern.
Business West Chambers & Initiative five areas of concern are:
1. The proposed locations for future housing development
The draft plan fails to set out a reasonable objective assessment for the location of future housing growth, particularly failing to consider the most strategic locations as determined by likely sustainability impact – for example in their closeness to public transport and the impact on commuting, congestion and carbon emissions.
The plan must be lead by these important factors, the best locations as determined by transport and sustainability, not by political considerations.
There has been a major failure to sensibly weigh the role and current shape of green belt against other important factors that should determine development locations. At present the political sensitivity of green belt has outweighed all other factors.
We believe that small releases of green belt close to existing urban areas should be considered as a way to deliver the most sustainable and environmentally friendly form of housing growth. The West of England should conduct a proper green belt review to identify land of low environmental and landscape value that can be developed close to good public transport links. In practice this will only release very small amounts of existing green belt, which could be ‘swapped’ with newly created green belt elsewhere.
2. The number of homes being planned is too low
Building the right number of new homes is vital if the West of England is to keep housing costs affordable and provide places to live for our residents, employees and their families.
We are concerned that the planned housing numbers remain too low.
Two independent pieces of work, one by the independent housing academic Professor Glen Bramley (which we commissioned) and the other based on guidelines set out by the government commissioned Local Planning Experts Group (LPEG), suggest that the West of England needs to raise its numbers considerably.
Glen Bramley’s work suggests that the current West of England numbers would lead to:
- a continued deterioration of rental affordability and homeownership affordability
- an increasing gap between jobs and population growth.
- a continued deterioration in owner occupation levels for the under 40s, but also for the 40 – 59 age group
- an increase in the number of people in affordable housing need
An important additional finding by Professor Bramley was that our housing affordability would deteriorate relative to the national average – undermining the West of England’s national competitiveness. Pressure on employer availability for jobs will also get worse – making it harder for local firms to hire new people.
3. The number of affordable houses proposed is too low
At present the West of England local authorities are openly acknowledging that they plan to fail to deliver nearly half of the identified affordable housing need (17,100 compared to an identified need of 32,000 – only 53% of the total) that the city region needs. We think that this is very hard to justify, both morally and economically.
A failure to deliver enough affordable homes will lead to a continued deterioration of housing costs and availability for low income households, higher pressures on social housing waiting lists and greater pressures on vulnerable households, probably leading to more households in temporary and emergency accommodation, as well as making it harder to recruit and retain key workers for the region.
The West of England should set out credible plans for how it intends to deliver the full amount of the affordable housing need that it has identified.
4. Not enough has been done to secure the future employment land that businesses will need
We are concerned that there is a lack of a proper consideration of future employment needs and provision for future employment land that the region will need if our businesses are to grow and create new jobs and wealth.
There are several areas of concern:
- The evidence base put together is weak and focuses too much on an assessment of ‘top level’ supply. This top level assessment relies too heavily on surplus land at Avonmouth, which requires significant infrastructural investment and will only be suitable for certain businesses. It does not examine what the growth projections are for individual businesses or sectors or how the West of England might provide the sites to attract future growth industries.
- The allocations put forward in the area’s two city centre Enterprise Zone (Bristol) and Enterprise Area (Bath) are too small when compared to the level of need identified.
- The projections for employment delivery in some other Enterprise Areas lack market credibility.
- The emphasis in the plan on switching employment to residential use could risk undermining many important city employment sub markets.
- The current plan emphasises growth in future employment land in identified Enterprise Zones and Enterprise Areas. This could undermine the employment land base in other parts of existing urban areas, as national government policy makes it much easier for developers to switch use from employment to residential uses. We would like to see safeguards introduced to secure these other employment areas.
5. Transport is not integrated properly into the overall plan
There are significant transport challenges associated with the spatial strategy and the strategic development sites located beyond the Green Belt. We are concerned that some of the proposed locations are not currently sustainable, implying large volumes of travel on sub-regional corridors and making the shift to more sustainable transport modes challenging. The level of transport investment needed to support these development sites will be considerable, and the extent to which this mitigation approach will be effective in promoting sustainable travel remains doubtful.
In other areas where there is a pressing need for transport improvements to support growth, the proposed vision is inadequate. The strategy does not adequately address Bristol’s lack of an orbital transport scheme around north Bristol, for example, in the high growth ‘Enterprise Arc’ between Avonmouth and Emersons Green, or around South Bristol, for example with the completion of the South Bristol ring road.