BWA has commented on the Joint Spatial Plan.
The Joint Spatial Plan for the West of England sub-region sets out plans to 2036 for housing growth and new employment locations, and also the infrastructure that will be required to support it. The latest round of consultation ended on 10 January, ahead of an assessment by a planning inspector later in 2018. Responses at this stage were required to focus on legal compliance, soundness and co-operation.
BWA commented that the draft JSP is unsound for the following reasons:
- The choice of Strategic Development Locations. The choice of SDLs is inappropriately constrained because of the failure to review the Green Belt.
- The balance of investment. Investment proposals are excessively weighted towards road building. There are insufficient specific commitments to investment in traffic management, improving walking routes and making new development walker-friendly.
The full response is here.
BWA is a member of the Sustainable Transport Network, which submitted comments on the JSP citing unsoundness for the following reasons:
- Too much weight has been given to protection of the Green Belt. The Plan’s choice of Strategic Development Locations (SDLs) strikes a sub-optimal balance between the twin aims of protecting the Green Belt and reducing the need to travel by non-sustainable transport modes. What is needed is a systematic review of the Green Belt.
- Some locations have been chosen to help justify the case for upgrading the transport infrastructure, which does not follow from the JSP’s strategic priorities. The expenditure on transport infrastructure, particularly roads, is more than it would need to be to support a more sustainable choice of SDLs.
- The match between the development areas and employment locations has not been demonstrated. The JSP contains no analysis to demonstrate that the match between the development areas and employment location minimises the need to travel as much as it could do.
- There is no commitment to transport project sequencing and prioritisation to align with strategic development plans, nor a mechanism for reviewing the SDLs should the feasibility or projected effectiveness of the transport schemes change.
The full STN response can be found here, as can links to responses by other members of Bristol Green Capital Partnership.