Bath and North East Somerset Key Requirements

Encompassing the urban core of the region, the Central Bristol & Bath growth zone has three distinct areas with strong investment potential:

• Central Bristol
• Bristol to Bath Corridor
• Bath City Centre

While each investment opportunity is distinct, cumulatively they will play a crucial role in transforming our region, delivering a significant proportion of the economic growth and development that will shape a bright future for our cities.

The Central Bristol and Bath Growth Zone is at the heart of the regional economy and is the powerhouse that drives growth across the West of England by attracting people, business, and investment. Encompassing two globally recognised cities within a 15-minute travel corridor, this growth zone attracts millions of business and leisure visitors each year, drawn by its rich history, iconic landmarks, and internationally renowned festival scene.

The Bristol to Bath Corridor

Bath and Bristol are currently two separate and distinct economic areas, and yet they are only 15 minutes apart by rail. If these economies were combined to one integrated conurbation, they would become the 7th largest in England. The Corridor between these two thriving centres provides and better joins the economies of our two cities. It will have exceptional connectivity by public transport and active travel into Bath, Bristol and beyond, offering sustainable and affordable access to work, education and recreation for both new and existing communities.

The Bristol to Bath Corridor offers an opportunity to do things differently, building a network of connected communities within the valley landscape. The River Avon valley and its tributaries provide the environmental capital for a new way of living and can drive forward a thriving nature-positive optimum density place.

Exemplar net zero and landscape-led sustainable housing developments and vibrant local businesses will create the standard for climate resilient placemaking and design. This will increase industrial and commercial capacity, job opportunities, and new homes of all types and tenures, including genuinely affordable homes. It will be unlocked through a well-connected, sustainable multi-modal transport corridor that offers a range of realistic transport choices and promotes active travel modes.

Bath City Centre

Bath City Centre is at the heart of the regional visitor economy and attracts significant visitor numbers and investment to the region. With the major new development of the Fashion Museum due to open by 2030, the city centre will once again evolve.

As well as strengthening the visitor offer, Bath City Centre will have a wide range of new employment sites that come forward in the next decade – located near a wide range of housing, the long-term vibrancy of this unique city is assured. Over the next decade, with investment for growth, we anticipate new businesses will locate in the city, strengthening the employment offer and contribution the city makes to national growth.

The Somer Valley Growth Zone encompasses the Somer Valley Enterprise Zone (SVEZ), industrial estates and the market towns of Radstock, Midsomer Norton, Westfield and beyond. This is to recognise both the regenerative impact of development and the needs of specific geographic areas. This zone can also offer an exemplar for development within market town locations - both for WECA as a whole and England. This zone reflects our strong ambitions for the area. Within this zone there will be a focus on sustainability and industrial developments.

This zone will also enable both the impact of regeneration and potential impact of economic growth. This zone offers a different model of support. This will balance the requirements and impacts of housing.

Within this zone the priority objectives will focus on:

• Supportive measures to enable the development of SVEZ and the potential future extensions
• Support for regeneration initiatives – including cultural infrastructure and activities – both in the town centres and connected to the planned new housing
• Transport projects esp. mass transit and bus initiatives

In light of the substantially increased housing need figure that we need to plan for, the council has reviewed and refreshed the economic evidence. In order to maintain the current balance between jobs and homes within B&NES, analysis suggests that an additional 25,000 jobs would need to be created and accommodated within the district. If job growth is below this figure and housing is delivered meeting the government’s latest figure of housing need, it is likely that increased out-commuting from B&NES will take place as people travel outside the area for work. Changes in working patterns and arrangements, including increased working from home will also need to be taken into account.

Key growth areas for jobs based on the forecasts are in the human health and social work employment sector; accommodation and food services (hotels, restaurants and bars etc); Information & Communication; creative/digital; and Professional, Scientific & Technical sectors. The latter sectors in particular are those that can help drive innovation and a more creative economy. In terms of sectors with a significant influence on employment land the evidence suggests there will be some decline in manufacturing and a decline in Transportation & Storage, alongside growth in the sectors outlined.

The increased jobs will be accommodated in many different ways and not all will be in sectors requiring traditional employment (office, industrial and warehousing) space. The updated evidence provides an indication of the amount of additional employment (office, industrial and warehousing) floorspace that would need to be provided in order to help deliver and accommodate the additional 25,000 jobs. These figures are set out in the table below and should not be treated as a target, but as a starting point in ensuring the Local Plan helps to facilitate sustainable economic growth and increased productivity.

Analysis has highlighted the ongoing need to deliver office, industrial and warehousing space and hybrid business space suitable for meeting modern occupier requirements, set against low levels of existing supply and historic development. This has created a challenging environment for potential and existing occupiers to fulfil their commercial property requirements within Bath and North East Somerset, and in particular, the City of Bath.

In terms of office floorspace the evidence notes that it is also possible additional floorspace will be released to the market as a result of workplace transition following the rapid increase in hybrid working following the Covid-19 pandemic. However, there still remains a degree of uncertainty over the long-term trend. Market evidence also indicates a strong preference for high quality modern space in locations accessible by public transport and with excellent amenity provision for workers.

In terms of industrial floorspace, there is currently a substantial under-supply in Bath City, Rural Areas and the Somer Valley. The evidence notes that given the constraints within Bath City, the Keynsham sub-area could play an important role in meeting some demand. Keynsham may also have a role in providing Research & Development space for growth sectors that can’t be accommodated within the city. At the same time as developing new areas, it is acutely important to protect existing industrial estates and sites.

In relation to warehousing and logistics space historically there has been a lack of warehousing development activity that has taken place across Bath and North East Somerset. This is due both to its relative unattractiveness to modern occupiers and constrained land supply in the right locations, with the right access and infrastructure provision.

The spatial breakdown of employment floorspace identified in the below is based on the existing distribution of employment space across B&NES and is therefore, only a starting point. In establishing the spatial strategy for delivering additional employment space other factors will need to be considered, including the sustainability of and connectivity and linkages between places, the proposed locations for additional housing and the locational requirements of businesses. Some site options for additional employment floorspace are set out in the place-based sections that follow. These comprise some site options solely for employment use, as well as the potential for some employment space delivered as part of mixed use developments on larger, strategic sites and opportunities to intensify existing areas of employment space.

The overall need for housing in B&NES set by the government’s standard method is for around 1,500 new homes per annum, or around 27,000 over the eighteen-year Local Plan period. This figure is derived from calculations by the government, which is based on increasing the existing housing stock by 0.8% per year and adjusted upwards to take account of the affordability (or unaffordability) of housing in B&NES. This is known as the ‘standard method’ housing figure. The standard method figure can vary year on year reflecting changes in the existing housing stock and if the level of housing affordability changes e.g. if house prices rise or fall or incomes change.

The government has also revised national planning policy to make it clear that it is mandatory for local authorities to plan for meeting the standard method figure of housing need. It may be possible for the council to seek to justify a Local Plan housing requirement below the standard method figure, but this is an increasingly high bar set by government. We have therefore set out options that would meet the standard method figure of housing need in full.

The LHNA shows that a significant proportion of projected population growth and therefore, overall need for new housing is comprised of projected growth in the student population.

The accommodation requirements of students are different to those of the rest of the population and for those aged 18-23 (primarily undergraduate students) are typically provided through student bedspaces e.g. in the form of Purpose Built Student Accommodation (PBSA). Given the significant projected student population growth and specific accommodation requirements we are considering options as to how this form of accommodation can best be provided. The provision of additional student bedspaces in PBSA would count towards meeting overall housing need (based on a government established ratio of 3.13 student bedspaces is equivalent to one dwelling).

Based on population projections the LHNA suggests a growth in the student population aged 18-23 of around 7,300. This would equate to around 370 student bedspaces per year. Although it is appropriate to understand the overall student housing need arising from the projected growth of student population based on long term trends, it is also important to ensure alignment with the future growth aspirations of the University of Bath and Bath Spa University. The council continues to work with both universities to understand their projected growth aspirations and therefore, to ascertain more likely future growth in the number of students. This should then form the basis for considering options for providing additional student accommodation. As the Universities are historically only able to provide forecasts for the next 5-10 years this element of future requirements and associated strategy will need to be kept under review.

The LHNA also provides more detail on the size, type and tenure of housing that is needed, including information on the need for affordable housing.

The plan period runs from 2025 to 2043. Some additional housing is already planned to be built on sites with planning permission and sites allocated for development in the current adopted B&NES Local Plan which runs until 2029. Sites with planning permission or allocated are known as existing commitments. Homes to be delivered on the existing commitments are deducted from the housing requirement to calculate the number of homes required to be planned for on new sites through the Local Plan. The spatial distribution of homes to be provided by existing commitments is illustrated in the map below.

In preparing a Local Plan we are able to make an allowance for housing likely to be delivered on small windfall sites, that is sites that will provide less than ten homes and will be granted planning permission without being specifically allocated for development. A windfall allowance over the plan period has therefore been calculated. Up until 2029 and for the remainder of the adopted plan period the existing figures from the published housing trajectory have been used. Beyond 2029 a realistic and relatively cautious approach has been taken based on past rates of delivery. Policy changes, including options to review Housing Development Boundaries for the towns and villages, may also affect likely small windfall site delivery. The small windfall sites allowance will be kept under review in light of annual monitoring of housing delivery and permissions. Further detail is set out in the Housing Topic Paper.

It is not just important to plan for the overall amount of housing that is needed. The LHNA identifies that there is a significant need for housing that is more affordable in Bath and North East Somerset and this corroborates evidence underpinning the council’s Economic Strategy. Affordable housing, as set out in the NPPF, has two main components i.e. housing that is needed for households that cannot afford market rents or prices to purchase, plus those households that can afford market rents but aspire to own their own home but cannot afford to do so. Based on both components the total future need for affordable housing in Bath and North East Somerset is significant at around 12,300 dwellings, representing around 46% of total general housing need in the district (split as 67% of housing need in the City of Bath and 38% of total housing need in North East Somerset).

Typically, the need for affordable housing of those that cannot afford to rent or buy will be met by either social rented accommodation or shared ownership homes (where the household buys a part share in the property). For those that can afford market rent but aspire to home ownership their need is typically met by either shared ownership or a discounted market housing product. The government is now placing an increased emphasis on the delivery of social rented accommodation in order to address the needs of those least able to access the housing market. The LHNA provides more detailed information around the different types of affordable housing need in both Bath and the rest of the district. This shows that in Bath 45% of overall future housing need is from those households that cannot afford to rent or buy and 21% is from those that can afford to rent but aspire to home ownership. The equivalent proportions for the rest of the district are 34% and 4% respectively.

With regards to the type and size of housing that is required across the district the LHNA provides useful information split between the City of Bath and the rest of Bath and North East Somerset. More detailed information for specific places or parishes can be gathered through Local Housing Needs Surveys. The LHNA identifies the largest proportion of housing that is needed is for 3 bed houses (around 32% of overall housing need) in both the city and the rest of the district. There is also significant need for smaller dwellings, 1 and 2 bed flats and houses, (around 18% and 24% of overall housing need respectively) for smaller households e.g. younger people and older people looking to downsize.

Finally, the LHNA also provides useful information on the significant need for more specialist housing for older people, both market and affordable housing, as well as information on needs of those with particular accessibility requirements.

The NPPF requires authorities to respond to and assist in meeting the unmet needs arising in neighbouring areas, as requested through the Duty to Co-operate, where it is reasonable to do so having regard to the principles of sustainable development. In responding to this requirement the capacity of Bath and North East Somerset to accommodate its own housing need, as set out above, in a sustainable manner is highly relevant.

At this stage and with the exception of Bristol City Council the neighbouring authorities to Bath and North East Somerset have confirmed they are seeking to meet their objectively assessed need for housing within their respective administrative areas. As such there is no request to help meet any of their unmet need. Through the preparation of its Local Plan, Bristol City Council have confirmed that they have capacity to provide around 1,925 dwellings per annum, or 34,650 over their Local Plan period. This capacity does not fully meet their locally derived housing need of 2,503 per annum or 45,054 over the Local Plan period. Bristol City Council, therefore, formally wrote to B&NES Council and also their other neighbouring authorities of North Somerset Council and South Gloucestershire Council in October 2023, to request that we explore whether we could accommodate a proportion of their unmet locally derived need of 10,404 homes. B&NES Council response to this request will be carefully considered through the preparation of our Local Plan. Under the government’s December 2024 revised standard method housing need figure for Bristol City Council the amount of unmet need has increased.

As part of the Climate and Ecological Emergency Strategies we're developing an Energy Strategy that builds on studies identifying enabling greater renewable energy capacity through the community energy approach as the best delivery model. Aside from the Core Strategy targets of 110MW electricity and 165MW heating, there is a widely used target of 300MW installed capacity across the authority area that was identified to be of the scale needed to help the area become carbon neutral. However, varying external factors relating to decarbonisation of the grid mean that this figure is likely to vary with time.

The council is part of a successful bid for Innovate UK funding for the West of England area that will enable the development of a Local Area Energy Plan in collaboration with the District Network Operator, that will identify detailed energy needs in terms of demand and infrastructure relating to the energy grids. This will help us to further refine our approach to planning and identify priority areas for delivery.

The constraints relating to grid connections (in particular those above 1 MW) remain a consideration in the short term for planning, although changes in the way reserved capacity queues are managed means that larger connections may be possible in shorter timescales and should not therefore be seen as a barrier to large renewable installations.

The Government is committed to an internationally agreed '30 by 30' target to protect 30% of our land and seas for nature by 2030. In addition, the government’s 25-year Environment Plan sets targets for restoring protected sites to secure their wildlife value; creating or restoring other wildlife-rich habitats; taking action to recover threated important species; and increasing woodland cover.

These government targets are reflected in the nature recovery targets set for the West of England, which have been adjusted for Bath and North East Somerset. New development will need to play its part in delivering these ambitions and the council is considering requiring 20% Biodiversity Net Gain (BNG) on sites that meet a specified threshold. It should be noted that the government is consulting on a proposal to simplify the BNG requirements relating to development sites of 10 to 49 dwellings or up to 1 hectare to help facilitate small-medium enterprises (builders) deliver housing.

West of England Nature Partnership (WENP) nature recovery ambitions adjusted for B&NES

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The Environment Act 2020 stipulates that each region in England must produce a Local Nature Recovery Strategy (LNRS), which will 'establish priorities and map proposals for specific actions to drive nature’s recovery and provide wider environmental benefits’. Local Plans must ‘take account of’ any relevant LNRS.

The relevant LNRS for B&NES is the West of England LNRS, which covers the unitary authority areas of Bath and North East Somerset (B&NES), Bristol, North Somerset and South Gloucestershire.

The West of England LNRS has now been approved and will guide and inform action for nature recovery. The areas mapped that ‘could become, of particular importance for biodiversity’ within the LNRS will also be used to define areas recognised as being of Strategic Significance within formal BNG calculations.

The council is also considering introducing and using Natural England’s ‘Green Infrastructure Framework - Principles and Standards for England’ (Green Infrastructure Framework), which includes standards for accessible greenspace, urban nature recovery, urban greening and urban tree canopy cover.

It is estimated that we need an additional approximately 200 ha of accessible greenspace across Bath and North East Somerset for the new homes (not accounting for unmet housing needs in neighbouring authorities) if we are to meet the accessible greenspace standard of 3ha per 1,000 population.

In planning for additional development we also need to assess and ensure likely significant adverse effects on European protected species and habitats are avoided or appropriately mitigated. This is addressed through a Habitats Regulations Assessment (further information is set out in the Strategic Principles page).

There is a clear emphasis throughout national policy and guidance on health and wellbeing in planning and placemaking. The NPPF states that planning policy should promote health and wellbeing. Paragraph 96 outlines that this should be achieved through promoting social interaction, making spaces safe and accessible, and creating places that enable and support healthy lifestyles. National guidance recognises health as a cross-cutting issue, which connects with and can be promoted by many policy areas within the Local Plan.

Key priorities of the B&NES Health and Wellbeing Strategy (2023) are to strengthen compassionate and healthy communities and create health promoting places. This includes utilising the Local Plan as an opportunity to shape, promote and deliver healthy and sustainable places and reduce inequalities. It also includes developing the infrastructure needed to build strong local communities and encourage proactive engagement in healthy lifestyles at all ages.

Transport systems and networks are essential in enabling everyday mobility and access and they need to become increasingly sustainable and inclusive to address climate emergency and social equity issues. The choices that are made through the Local Plan are integral to the sustainability of our district as a whole, including influencing where development is located, and how we enable more sustainable travel choices for our existing and future communities. Our district requires mobility of people, goods and services to fulfil the needs of the population who live, work and visit B&NES. This demand for mobility will increase as a result of housing and employment growth to be facilitated through the Local Plan. This presents a core challenge to accommodate this increased mobility need whilst supporting progress towards our Climate and Ecological Emergency commitments.

Bath and North East Somerset has an ambitious aim to deliver the forecast growth within the Local Plan as part of its drive towards the decarbonisation of transport across the district. We cannot continue to predict and provide for increased traffic capacity, because it enables further car usage, leading to car-reliant communities and our places becoming dominated by private vehicles. We need a change in approach where the transport network is rebalanced in favour of sustainable modes, to provide more options for people to get around. So, through this Local Plan, we will take a ‘vision-led approach’ by setting an ambitious and aspirational transport vision with and for Bath & North East Somerset, to support existing and new communities with attractive sustainable transport networks and realistic alternatives to the private car. Our approach follows the sustainable transport hierarchy. In the first instance, we seek to utilise the Spatial Strategy, and the site selection process, to locate people close to the services and facilities that they need, e.g. employment, education, health, retail, leisure, public transport. The Evidence Base documents set out greater explanation of the process we are going through to develop this Transport Strategy.

We recognise there are a range of challenges and opportunities for transport across the district, and that there is significant variation in levels of connectivity and car reliance. We also recognise that the planning process can only directly apply to new development, or redevelopment, limiting the scope of influence of the Local Plan. However, it is clear that to accommodate housing and employment growth sustainably, we must enable people currently making trips by car to choose a more sustainable alternative.

Addressing the wide range of transport issues and opportunities people face across our district requires a holistic approach, delivered through the Local Plan and a range of transport plans and programmes, including with the West of England Combined Authority as the strategic transport authority and the facilitators of significant transport investment from central government to support growth.

We have embarked on a programme of transport strategy, scheme identification and modelling as part of the Local Plan process. This Options Consultation is a key stage in this process to test and further refine our emerging transport vision for Bath & North East Somerset, for existing and new communities. This will be via mapping the outputs of the adopted Creating Sustainable Communities strategies for North East Somerset to the community and other stakeholders. Following this, we will develop the transport vision, strategy and evidence base further as we progress towards the submission and Examination of the Plan.

We are also investigating strategic approaches to enhancing sustainable transport across the district. This includes improving the function of the Park and Ride sites to be “Transport Interchanges”, providing a greater range of travel options than car to bus, and into-out of city centre. We have also developed, consulted on and adopted an Active Travel Masterplan for the district, to provide people with improved opportunities to travel by walking, wheeling and cycling. The transport evidence base will also help set the vision for public transport across the district, including for bus, rail and future mass transit as key components of shifting medium and longer length trips within and outside of Bath & North East Somerset.