In January 2022 North Somerset Council published its preferred options for how it plans to accommodate the 20,085 dwellings the government say we have to plan for. The proposals included a significant development of 2,500 homes next to Long Ashton, on and around Woodspring Golf Course.

In March there was a public meeting co-hosted by your two North Somerset Councillors (Ashley Cartman and Stuart McQuillan) and Long Ashton Parish Council, attended by planning experts from North Somerset Council to explain the reasoning, process and answer questions. This meeting formed part of the consultation process.

The Parish Council, in consultation with residents, responded to North Somerset Council's consultation (as given below). In addition, a supplementary letter was provided. Plus, the Parish Council supports the following motion put forward by residents at the Annual Parish Meeting.

'This Council supports the desire of villagers for the protection of the valuable and irreplaceable Greenbelt land around Long Ashton including that at Woodspring Golf Course. We question whether the 2500 houses, the size of another Long Ashton, on this land are needed, given the numbers are calculated by central Government algorithm. We also question whether North Somerset Council has done enough to exhaust all options for development outside the greenbelt. We feel Greenbelt is more essential than ever for wellbeing, wildlife and as a resource to combat climate change. When it is gone we can never get it back. This is the tip of the iceberg. Developers will pounce on more spaces around us to render us a suburb of Bristol. We know affordable housing is needed in the UK but not at the expense of the Greenbelt.'

Dear Richard Kent (North Somerset Council, Head of Planning),

Although we have completed the questionnaire on your website we have been unable to fully express the views and concerns of our residents. Therefore I am asking you to accept this letter as part our response as a parish council to the consultation.

Our concern is that the proposal to build 2,500 houses in the green belt on the proposed site centred on the Woodspring Golf Course and inside the SBL at Lime Kiln Roundabout will become the first resort for development not, as it should be, the last resort.

Of course many people living elsewhere in North Somerset will call our concerns nimbyism, but we can honestly say that Long Ashton has taken more than its fair share of landfill sites and development. It is already the size of some small towns and at the limit of what can be called a village but lacks the appropriate facilities. We have lost our children's centre and our library. We do not want to lose our green belt as well.

On a national and global level, the IPCC report published in April 2022 should focus our minds on the true value of the green belt. Warming in Europe is set to continue faster than the global mean and that will increase cooling needs, food and water demands.

Fire prone areas are projected to expand across Europe at the same time as severe flooding events. Yet one of the main, quickest and cheapest ways to mitigate climate change is the restoration, expansion and connection of protected areas for ecosystems so why destroy a huge chunk of green belt land that is already mopping up carbon and providing a vital link between the Avon Gorge, the Lakes and the Mendips?

On a more local level, the past two years have illustrated the value of the green belt not just to us but to the people of Bristol who escaped the privations of lockdown by walking, running and cycling in the woods, parks and fields in our parish. It also demonstrated the vulnerability of the green belt to heavy use. Vegetation from bluebells and anemones to hedgerows and woods were damaged by sheer over-use. Small birds and mammals were visibly less present due to habitat disruption. Farmers complained of sheep-worrying, litter and fly-tipping. At last the land is beginning to recover but this experience demonstrates that the woods and fields cannot tolerate more intensive use.

Building 2,500 houses on many hundreds of acres of green belt land will not simply reduce the amount of green belt but will significantly reduce the wildlife corridors linking Ashton Court, Tyntesfield and Failand and prevent the implementation of the nature recovery networks identified by the West of England Nature Partnership. These proposed networks are invaluable to create a resilient ecosystem that is better suited to cope with the extreme weather events imposed upon us by climate change.

More pressure will be put on the ecosystem by increasing the number of people using the land for health & well-being. Bristol's plans to build Longmoor village and redevelop the Cumberland Basin will attract thousands more people who will also need access to good quality greens and bluespaces such as parks, woodlands, fields, streams and ponds.

The review from Public Health England in 2020 shows that good quality greenspace can help bind communities together, reduce loneliness and mitigate the negative effects of air pollution, excessive noise, heat and flooding. Disadvantaged grqups such as those, one could argue, living in south Bristol appear to gain a larger healthy benefit when living in greener communities or with easy access to good quality green and bluespace.

Anyone who lives outdoors might instinctively feel a boost from spending some time in our parks or woodlands but it is now formally recognized that green environments are associated with reduced levels of depression, anxiety and fatigue and can enhance quality of life for both children and adults.

In addition, the green belt should prevent the unrestricted sprawl of built up areas but, as your own assessment has concluded, building on the Woodspring site 'would constitute sprawl.' Allowing one development within the green belt will legitimise further development. We expect that Taylor-Wimpey will respond to your consultation by arguing for further development but as the paragraphs above show we wonder how Taylor Wimpey can ignore the problems that are at our door? Is the company thinking of the long-term future of our children and their children? Or simply, in the short term, its profit margins? To us, living in a world that is predicted to experience unprecedented change such corporate blindness is simply unacceptable.

We would also like to note that the green belt exists to prevent neighbouring towns merging into one another. Combined with the development inside the SBL and the expansion of the Barrow Hospital site, the proposal under consideration will create a continuous strip of development from southwest Bristol to Wild Country Lane. Your own assessment of the green belt recognises the risk of the merger of Bristol with Nailsea and Backwell, and the consequent loss of identity for Long Ashton.

North Somerset Council has declared a climate emergency and in 2020 declared a 'nature emergency' stating that the threat of mass extinctions and loss of biodiversity must be at the heart of every decision North Somerset Council makes. The Woodspring Golf Course has some outstanding habitats including mature shelter belts of native trees and shrubs, an extensive water catchment area with ponds and water courses and areas of long grass that shelter voles and mice. Swallows feed in the skies above; barn owls, kestrels and buzzards hunt over the grasslands. Since the membership has declined from 2000 members to 49, the area has become a refuge for many animals. Before long, skylarks could join the throng.

We understand that building within the green belt should be a last resort but you have informed us that if these proposed developments become part of the local plan you will be unable to prevent builders, who already own this land, developing it before they build on brownfield and other sites outside the green belt. In other words these developments could become the first step in a massive development that will merge Dundry, Barrow Gurney and Long Ashton with Bristol. For this reason alone development within the green belt must not be included in the local plan.

Instead we recommend that:

• You challenge the algorithm that generated such a high and unsustainable target for development - even join with other councils experiencing the same problems.
• You make greater use of sites outside the green belt including the garden villages proposed in earlier plans, low-lying areas (not flood plains), brownfield sites, and consider the scope for development in those villages where it would make local facilities more viable.
• You recognise the changes in work patterns that have been accelerated by the internet and Covid. Those that can work from home do work from home as much as possible and look for facilities close to home. Town centre shops, offices and car parks are underused and need redevelopment to bring life back to local communities.
• You consider radical alternatives such as forming your own development company, in preference to working with the big building companies who have completely lost the trust of local people by

1. building below specification (see the recent University College London report)
2. the transfer of community land to a private company that conspicuously fails to deliver its obligations (e.g. Dawson Walk)
3. the dilatory dealing with s106 obligations e.g. public art and Peel Park.
4. negotiating down the proportion of affordable housing

Yours Sincerely,

Catherine Fagg, Chair, Long Ashton Parish Council

OUR VIEW: Support with amendments

The proposals allocate 18,046 houses, a shortfall of 2,039 from the governments housing target for North Somerset.

We question the basis upon which the government's algorithm has calculated North Somerset Councils housing allocation. We agree that new housing needs to accommodate the natural population growth of North Somerset as well as provide for some people moving into the area. However, the number allocated seems to provide housing for significant population migration from other areas. These excessively high numbers appear to be justified upon the spurious basis of 'affordability'.

Additionally, North Somerset has extensive tracts of land classified as either green belt, land susceptible to flooding, or as an Area of Outstanding Beauty. This makes it harder for us to accommodate significant housing growth than other areas of the UK. We believe no consideration has been made for these restrictions in calculating our share of national housing targets.

We ask that North Somerset Council write to government to both question the basis of the housing allocation and to request that our numbers be reduced by at least the current shortfall on the draft proposals.

If, as we expect, this is unsuccessful, then the shortfall should be allocated outside of the green belt. We agree that the shortfall should be allocated rather than left as unfulfilled or unallocated.

Our view is that North Somerset Council has failed in its duty to properly consider sites outside of the green belt. It is of paramount importance that any further allocation should not permit the urban sprawl of Bristol. Accordingly, the following sites/areas outside of the Green Belt should be reconsidered:

• Development of policies to both facilitate the concentration of retail premises into town and village centres and to make it easier and quicker for former retail sites to be converted to residential use.
• Many villages have been excluded from development meaning that new housing growth is concentrated in several strategic, or semi-strategic, locations. These villages could become much more sustainable with a moderate amount of growth allowing the communities to reach a critical mass that would support the provision of local services. This would also spread the 'burden' of development more fairly across the district as well as tend to favour small local housebuilders.
• Low lying land has been excluded unnecessarily. We object to building on flood plains but there are low lying sites where appropriate sustainable flood resistant development could occur. Just because this costs the developers more should not be a reason for developing on the green belt instead.

OUR VIEW: We support NSC's ambition to provide 40% affordable housing with the following amendments/comments

• The proposals should apply to all sites of 5 or more houses, rather than 10 as proposed. Small sites, perhaps under 10 houses, could, if necessary, have a reduced requirement of 20%.
• The definition of 'affordable homes' needs to be widened from the current definition as 'housing for sale or rent for those whose needs are not met by the market'. In addition to providing 'housing for rent, starter homes, discounted market sales housing' consideration needs to be given to, for example, providing affordable housing for families and the elderly. We welcome NSC's commitment to develop a Supplementary Planning Document in this area.
• A holistic view needs to be taken of the type and quality of the total housing stock in North Somerset. Using demographic data, we should seek to predict demand for future types of housing and plan accordingly. For example, more bungalows may be needed to allow the elderly to downsize.
• Homes not only need to be affordable to buy but also affordable to live in. Recurring energy costs can be reduced by good house design. North Somerset Council's standards and building policies should written to maximise the energy efficiency of new homes.
• Too often developers promise affordable housing only to renege on the basis of their own supposed 'affordability'. The Council need to be more forceful in ensuring developers keep to their promises. We would support the use of tax payers money to employ or contract additional specialist staff that could challenge developers to ensure they keep to their promises.

OUR VIEW: Support

SP9 notes 'around 30ha of additional land to be identified at the strategic growth areas'. It is noted that 10 hectares of this is to be found at Woodspring. If the Woodspring site is allocated, we welcome the integration of employment land into the site. This should help build a more economic and environmentally sustainable community. We support this as a principle of strategic planning across the district.

Our view is that the 10 hectares allocated at the Woodspring site is adequate for both the new development as well as the existing community. We would oppose any further land being allocated at this location.

Too many people already commute into Bristol from other parts of North Somerset. Any additional requirements for employment land should be met elsewhere in the district to encourage and enable people to work closer to home.

OUR VIEW: Object

The National Planning Policy Framework sets out very clearly that 'Green Belt Boundaries should only be altered where exceptional circumstances are fully evidenced and justified' (NPPF para 140). Furthermore, the NPPF states that before concluding that an amendment to the Green Belt is necessary 'the strategic policy making authority should be able to demonstrate that it has examined fully all other reasonable options' (NPPF para 141). North Somerset Council has not fully examined all other reasonable options.

In support of our view, we present a number of issues where we believe further examination is required.

1. Garden Village proposals outside of the Green Belt have been discounted without sufficient justification. Changing patterns of work post Covid as well as the coming decarbonisation of transport make the sustainability considerations less pertinent. A garden village outside of the Green Belt was proposed as part of the previous Joint Spatial Plan put forward by NSC in conjunction with neighbouring local authorities. No justification has been given for its exclusion from these proposals. In accordance with the legislation sites like this should be properly considered before Green Belt development.
2. Low lying land (not flood plains) has been excluded. Modern design and construction techniques mean that homes can be developed that are resistant to flooding. These sites (eg near Clevedon) have been excluded without any serious justification. The amount of S106 and CIL contributions from developers should not influence the outcome.
3. Covid has seen an acceleration in the shift to online retailing, leaving many of our town centres with vacant premises. Retail accommodation should be repurposed into residential; this would take the pressure off the Green Belt. Planning policy should be revised to make this easier and to encourage the consolidation of remaining retailers into village and town centres.
4. With smaller town centres the need for car parking has diminished. North Somerset Council should look at car parking across the district with a view to identifying those site suitable for residential development.
5. Many villages have been excluded from development meaning that new housing growth is concentrated in several strategic, or semi-strategic, locations. These villages could become much more sustainable with a moderate amount of growth allowing the communities to reach a critical mass that would support the provision of local services. This would also spread the 'burden' of development more fairly across the district as well as tend to favour small local housebuilders.
6. We question whether all sites outside of the green belt identified in previous local plans have been built upon. The legislation is clear; the green belt should be the last option. It is simply wrong to build on green belt when other sites with planning permission remain to be developed. If the green belt is released then these existing sites, as well as new sites outside of the green belt, are more likely to be land banked by developers as they build out on more profitable green belt first. You end up with the farcical situation where green belt development happens first rather than last. This is unacceptable.
7. By releasing some of the green belt you undermine the ability of future generations to protect what remains. Land currently classified as high value green belt would be undermined by the proposals making it easier for developers to build upon in the future. The current proposals represent the 'thin edge of the wedge'.
8. The Green Belt is a valuable resource for residents not only of Long Ashton Parish but also of Bristol. By developing part of it you either increase the pressure on what remains and hence degrade it further, or force people to travel further to access green open space. We need to put people above profit.

OUR VIEW: Object

No, the balance is completely wrong.

We need to enable a diverse range of housing stock. This includes rural as well as urban locations. The current plans see new housing pushed into limited high-density locations. It will accentuate a rural urban divide where increasingly only the wealthy can afford to live in the countryside. Housing should be provided across the district and not just in 'strategic locations'.

As noted above, the combination of the rapid decarbonisation of transport and changing work patterns have weakened the sustainability arguments for concentrating development into a small number of areas.

We propose two amendments:

• All villages outside of the green belt should be assessed to see whether a reasonable amount of growth would allow the community to reach a critical mass that would in turn support the provision of key local services currently absent. Where such villages exist then sites should be allocated accordingly.
• To provide a more equitable balance between urban and rural developments all villages not covered by the above should have sites allocated to accommodate housing growth of 5%-10%.

These measures would ensure a more equitable distribution of new housing growth and be a better reflection of where our residents want to live.

OUR VIEW: Support with amendments

We welcome recent changes to the National Planning Policy Framework that allows councils to refuse planning permission for poor quality, and poorly designed development. In turn we support policy SP4:Placemaking which seeks to set out what good development means in the context of North Somerset.

With regard to this we propose three amendments/comments:

• SP4:Placemaking is very generic in its description of what constitutes good design. We believe the policy should be more detailed with explicit reference to what good design looks like in North Somerset.
• A recent study by University College London has found that the Planning Inspectorate, in support of the Governments lead, is three times more likely to back councils in rejecting developer poor quality proposals from developers. North Somerset Council should ensure it is robust in challenging developers to meet high standards. To facilitate this, it should ensure it has the appropriate number of qualified staff.
• North Somerset Council has some scope to set the quality of new homes. Although higher quality homes are more expensive to build and could undermine affordability objectives, we believe that such additional cost is minimal. Therefore we ask that North Somerset Council set the highest possible standards for new homes.