Saltford Parish Council has written to B&NES Council’s Head of Planning to formally raise its concerns about the Local Plan Options Consultation. The concerns were resolved at SPC’s May 2024 meeting (Item 13.f).
Further to recommendations made both before and during the Local Plan Options Consultation (more on the latter can be found in SPC’s article ‘B&NES Council acts following SPC concerns about Local Plan Options Consultation process‘ (published 19 March), a number of other concerns were also discussed at SPC’s May meeting.
Saltford Parish Council has expressed to B&NES Council that it sincerely hopes that the concerns expressed will be noted by B&NES Council, resulting in issues being addressed and recommendations being taken onboard by the time of B&NES Council’s Draft Local Plan consultation.
A copy of SPC’s formal concerns can be found here and also copied below, as follows:
SPC CONCERNS TO BE SUBMITTED TO B&NES COUNCIL RE. LOCAL PLAN OPTIONS CONSULTATION (12 Feb – 16 Apr 2024)
1. THE “CLICK TWICE TO SUBMIT” & RELATED ISSUES INCL. NEED FOR EMAIL RESPONSE OPTION
On 12 March SPC Cllr Phil Harding and Ward Cllr Duncan Hounsell identified and reported to B&NES Council the misleading need to ‘click twice to submit’ a response. SPC followed this up the same day with a similar report to B&NES which included recommendations to raise public awareness of – and importantly to rectify – the ‘click twice to submit’ issue. B&NES responded the same day stating that it would keep the ‘click twice to submit’ and include the need to do this in a press release.
(B&NES Council then mentioned the ‘click twice to submit’ issue in a press release about changes to Farrington Gurney’s options consultation information – e.g. not ‘headline news’ – but quite far down in the article and likely only to be read by those interested in that village’s maps etc.).
On Thu 14 March SPC responded to B&NES – after not receiving anything further to the press release mentioned – to reiterate its concerns and recommendations and to urge B&NES Council to take action to address. It also rebuffed B&NES Council’s claim on 12 March that as B&NES had received many responses the form was working. See below.
On Tue 19 March, i.e. over a month after the consultation had first commenced, SPC received the message from B&NES saying it had taken the actions recommended by SPC and also extended the end date of the consultation from 8 April to 16 April.
SPC is also concerned that after a respondent clicks the submit button and waits for the page to refresh (if the respondent has noticed the advice note on the web page about need to do this), when the page refreshes it returns to the top of the page rather than showing the response reference no. which appears at the bottom of the page but is out of sight to the respondent unless they think of scrolling down the page to try and see if the response was accepted.
In future it would be helpful if the acceptance of the response and its reference number appeared at the top of the page when the page refreshes with clear instructions at the bottom to wait for the page to refresh and the reference number to appear.
Parish Councillors and others (e.g. staff at our Community Post Office and Library) had to spend considerable time helping residents, including those who would be considered IT literate, to navigate the system to find the appropriate sections for submitting a comment. The layout was confusing, complex and off-putting for respondents, some of whom may have decided it was too much trouble and decided not to participate.
There is a high risk that many responses will have been lost and not accepted by the system as (i) residents may have moved off the page without clicking SUBMIT twice for a significant proportion of the time period that the consultation was open (i.e. ‘the click twice issue’ was resolved on 19 March, the original end date was 8 April, this was extended to 16 April, therefore the issue existed for 5 weeks 1 day out of an original 8 week consultation, which was extended to a 9 week 1 day consultation thus for over 50% of the entire time the consultation was open), and (ii) responses may have been lost when respondents moved off the page before the response was properly submitted.
Parish Councillors have received numerous comments and concerns from residents that their responses may or may not have been received and that they have no way of knowing as they cannot recall afterwards whether they had provided an email address. The lack of clarity and somewhat complex means of navigating the significant number of Sections requiring responses were off-putting factors that may reduce the accuracy of the overall consultation response and caused a significant time commitment for SPC and others seeking to help residents who wanted to respond but were finding it difficult and misleading. This was also stressful for those residents with a strong wish to make their views known but finding the whole process confusing.
Taking account of the above concerns and the several difficulties encountered by many residents, the lack of an email response option was a false economy by B&NES that has reduced the value and scope of the consultation process and puts B&NES more at risk of a legal challenge over the validity of the consultation process.
On 15 January 2023, before the consultation commenced, by email to Planning_Policy@bathnes.gov.uk SPC requested an email response option. The inclusion of that option would have enabled greater participation by more members of the community. Furthermore, Parish Councils in any event should have an email response option for their more comprehensive responses due to their active roles, knowledge and responsibilities in planning.
2. WITHIES GREEN MAP
The maps produced by B&NES Council connected to the consultation that showed existing allocations and site options were inaccurate with regard to the existing Withies Green allocation in Keynsham. The map(s) failed to show the south and westward tail of the development by Curo that if included would have shown a gap of only 160 metres from the proposed West of Saltford development option.
As the 160 metre gap is inadequate for the purposes the Green Belt serves of providing a check on the unrestricted sprawl of large built-up areas, preventing neighbouring towns/communities merging into one another, safeguarding the countryside from encroachment, and preserving the setting and special character of historic towns (and villages), this would have further identified the unsuitability of the west of Saltford option had the map been more accurate which may, therefore, have been removed at the HELAA stage and not be included in this consultation.
3. ORIGIN OF RESPONDENTS (POST CODES)
As some respondents may consider it appropriate to strongly or partially support developments in other areas of B&NES to reduce the risk of their own community being subjected to yet more new housing developments, it would have been sensible to ask respondence to include their post code in their responses, and make that a requirement for a valid response.
Without that requirement any analysis of the responses will be less accurate when trying to determine the level of acceptability or unacceptability of proposed options for development.
4. MISSING QUESTION ON DEFINED LANDSCAPE SETTINGS (& PLANNING STRATEGY)
In his email of 25 January 2024 concerning SPC’s request for a landscape designation for Saltford south of the A4, Cabinet member Cllr Matt McCabe said there would be “A question around the defined landscape setting of settlements, providing stakeholders with the opportunity to submit comments relating to and seeking changes to the landscape setting of the village.”
No such question was in the Local Plan Options Consultation which SPC consider to be a serious matter as the creation or review of a Local Plan provides the only opportunity for a community to seek a landscape designation.
Furthermore, SPC had been asking B&NES Council for this inclusion in the Local Plan consultation since January 2023 – see timeline below. SPC will be writing separately to B&NES Council about this serious omission and the management of SPC’s request before the consultation for a landscape designation.
Related to this issue is that by only allowing the online consultation process to respond to individual sections and not allow comment on the overall planning strategy to be adopted, limits responses to questions asked by B&NES and does not allow the wider community and in particular the views of Parish Councils to be expressed on the overall planning strategy proposed for the next twenty years or so. This is a democratic failing in the overall process.
Saltford Parish Council
7th May 2024
Saltford Landscape Designation (AGLV, LGS or NE2a) Request Timeline
| 3 Jan 2023 | SPC resolves its “Area of Great Landscape (AGLV) or Local Green Space (LGS) designation for Saltford South” submission paper (sent to B&NES Council 4.1.2023) |
| 3 Jul 2023 | At Local Plan meeting between B&NES Council, SPC and Keynsham Town Council, the AGLV designation submissions were on the agenda. SPC asked B&NES Deputy Head of Planning if B&NES required further information on the submission paper or if it needed to be discussed at the meeting. The response was that the submission was ”thorough as it is” for B&NES’s needs. |
| 20 Nov 2023 | At Local Plan meeting between B&NES Council, SPC and Keynsham Town Council, SPC’s AGLV request was dismissed, almost as an aside, as B&NES Council doesn’t use the AGLV designation and is proposing to stick with existing NE2a designations; it didn’t want to lead to other communities seeking an AGLV designation [NOTE: this is not a planning reason to dismiss SPC’s request]. |
| 3 Jan 2024 | In view of dismissal of landscape designation request, SPC resolves to submit to B&NES Council a new paper “Landscape designation for Saltford South: Reaffirmation of application with outcome options” (sent to B&NES Council 4.1.2024). |
| 25 Jan 2024 | Cllr Matthew McCabe, Cabinet member for the Built Environment, Housing and Sustainable Development, emails SPC to say B&NES does not propose designation an AGLV on land at Saltford, as the Council’s approach to landscape designations does not recognise or use AGLV. It uses NE2a (Landscape Setting of Settlements) which effectively achieves the same outcome, but that approach was established in the 2017 Placemaking Plan. [Note the 3.1.2024 reaffirmation paper from SPC did offer to accept an NE2a designation.] Cllr McCabe also said that a question around the defined landscape setting of settlements would provide stakeholders with the opportunity to submit comments relating to and seeking changes to the landscape setting of the village. |
| 7 Feb 2024 | SPC replies to Cllr McCabe stating it is disappointed that the bid has been rejected by B&NES Council at this early stage in drafting the Local Plan with no formal criteria and decision-making process within B&NES Council for reaching that decision, etc. |
| 12 Feb 2024 | B&NES Local Plan Options Consultation commenced (until 8.4.2024). No specific question around the defined landscape setting of settlements, including such a question for either of the two Saltford options. |
| 5 Mar 2024 | SPC resolved its response to the Local Plan Options Consultation AND resolved a new paper “The Saltford Area of Great Landscape Value – Planning Policy and Character Appraisal by Saltford Parish Council (March 2024)” as supporting evidence [response sent 6.3.2024 by post and email]. In the response SPC also said it “shall seek direct discussion with B&NES Council Planners on this specific matter”. |
| 7 May 2024 | SPC resolved to submit an official complaint to B&NES Council’s Chief Executive, Will Godfrey, re. management by B&NES of the landscape designation request. |