SPC adds to its response to Local Plan Partial Update (LPPU) consultation - Saltford Parish Council

Planning decisions in Saltford (being under B&NES Council, the Planning Authority) are guided by National and local Planning Policy. The Local Plan is reviewed every five years, to determine whether it remains fit for purpose or requires updating. There will be a full review of the Local Plan alongside the West of England Combined Authority Spatial Development Strategy (SDS) in 2023.

B&NES Council is currently making a Partial Update of the Local Plan to address a number of urgent issues, and consulted on these in 2021. Following feedback (including a response from Saltford Parish Council) B&NES Council has progressed the plan by submitting it to the Secretary of State for Examination in Public. A public examination is part of the legal framework required to change the Local Plan. Planning Inspector, Mr Philip Lewis BA(Hons) MA MRTPI has been appointed to undertake an independent examination into its soundness.

SPC has been informed that the examination into the soundness and legal compliance of the Bath & North East Somerset Local Plan Partial Update (LPPU) will will commence at 09.30am on Tuesday 21st June 2022 within the Elwin Room of the Bath Royal Literary & Scientific Institute, 16 – 18 Queen Square, Bath, BA1 2HN. The Hearings will continue for a second week and will reconvene at 09.30am on the 5th of July 2022 within the Brunswick Room of The Guildhall, High Street, Bath, BA1 5AW.

If it is approved, B&NES Council is seeking to adopt the version submitted as the future framework for decision making on planning until the new Local Plan is adopted in 2024.

A plan adoption timeline is on the B&NES Council website.

A website for the Examination has been established and will be regularly updated throughout the process:https://beta.bathnes.gov.uk/local-plan-partial-update-lppu-public-examination

At its May 2022 meeting, SPC resolved to submit a Hearing Statement (additional written comments) to the examination, further to its resolved response to the Local Plan Partial Update (LPPU) consultation as agreed at its 5 October 2021 meeting (more information about the B&NES Council 2021 LPPU consultation can be found here).

The Hearing Statement as agreed on 3 May 2022 and subsequently submitted to the examination is as follows (copy also available here):

Saltford Parish Council representation (approved by SPC 3.5.2022) to the Examination into the soundness and legal compliance of the Bath & North East Somerset Local Plan Partial Update (LPPU)

Question from the Inspector addressed by the new evidence in this representation: –

Matter 4: Area Policies and allocations: Keynsham

Question 57 “The explanatory text to the adopted Core Strategy and Placemaking Plan states that Policy KE3B safeguards land at East of Keynsham for development beyond the end of the plan period. What is the justification for the proposed allocation of this land now, and is the allocation of the land consistent with national policy as expressed in paragraph 143 of the NPPF?”

Due to recent evidence described in this representation and for reasons of Government Planning Policy, SPC requests that the proposed deletion of policy KE3B (Safeguarded Land at East Keynsham) be cancelled to prevent the inappropriate bringing forward before the end of plan period (2029) of additional housing developments of 280 dwellings in policies KE3C (East of Keynsham), 210 dwellings, and KE3D (East of Keynsham Safeguarded Land), 70 dwellings by Minsmere Rd.


Further to Saltford Parish Council’s original representation of 5 October 2021, B&NES Council publicised in January 2022 data from the Government’s annual Housing Delivery Test (HDT) revealing that B&NES Council is far exceeding the targets set in its Local Plan to deliver new homes for residents.

In the past three years before January 2022 (2018-19, 2019-20 and 2020-1) 3,100 new homes, including 700 affordable homes were built across the district representing a delivery rate of almost double at 184% of the target of 1,688 set in the Local Plan.

Despite this success rate in building new homes, B&NES Council is nevertheless proposing to bring forward the building of 280 new homes on safeguarded Green Belt land between Saltford and Keynsham through deleting policy KE3B to bring forward policies KE3C and KE3D despite the existing harm arising from recent new Local Plan housing developments in Keynsham as described in our original representation (at Annex).

If those unsound policies (KE3C and KE3D) are permitted to proceed, despite B&NES Council’s high success rate in building new homes, that will contribute further to severe road congestion in the Keynsham area due to insufficient transport infrastructure whilst losing valuable green space and its potential use for ecological recovery.


The high proportion of Green Belt and AONB in Bath and NE Somerset puts a responsibility on B&NES Council to protect that land from development and set lower housing delivery targets than the standard method allowed by Government in such situations unless there are fully justified very special circumstances; Saltford Parish Council has seen no evidence that lower targets have been set.

B&NES has provided no justification or sound evidence of the very special circumstances required (NPPF 2021 para. 140 and 147) to permit the new development proposed for safeguarded Green Belt land (KE3C and KE3D) within the plan period to 2029, i.e. for bringing those developments forward by deleting policy KE3B.

Those housing developments are unnecessary, do not contribute to sustainable development (i.e., are contrary to NPPF 2021 paragraphs 8b – social, 8c – environmental, and 143a – for meeting identified requirements for sustainable development) and will exacerbate the harm to the local community in and around Keynsham arising from the existing delivered Local Plan developments at Keynsham as described in our original representation. That representation is reproduced at Annex for reference and covers policies KE3C & KE3D:-

· housing land supply: the lack of green space (i.e. non-provision of new public parks) to cater for the residents of the new housing in the existing Local Plan resulting in harm to remaining local Green Belt and wildlife habitats;

· Transport: namely traffic congestion and consultation request for Saltford Station site options; and

· Biodiversity net gain: higher targets, use of local knowledge, and implementation timing.

Saltford Parish Council (3 May 2022)

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