Last week, planning inspectors examining a ground-breaking joint strategic plan (JSP) advised the four councils involved that they should withdraw the document. They told Bath and North East Somerset, Bristol City, North Somerset and South Gloucestershire Councils that "fundamental aspects of the plan" – the first in the country to take the approach – were not sound. The letter could have big implications for development in the council areas and for other areas drawing up similar documents.
The planning inspectors’ letter requested more evidence from the plan’s promoters about a number of aspects of the plan. In particular, it said they were "not persuaded that there is evidence to demonstrate that the Strategic Development Locations [for large-scale housing schemes], and thus the overall spatial strategy, have been selected for inclusion in the plan, against reasonable alternatives on a robust, consistent and objective basis."
Paul Jobson, director in the Bristol office of planning consultancy DLP, says that the councils ran into difficulties because they "simply divided up the housing requirement rather than developing a joint strategy based on the most suitable, available and deliverable sites". He adds: "Robust sustainability appraisal and consideration of reasonable alternatives are all fundamental to sound plan-making, so I can understand why the inspectors are unconvinced that a coherent strategy has been submitted."
The inspectors have cancelled scheduled hearings into the plan for September and October, but said they will write to the councils again in mid-August, setting out their concerns in more detail. They said: "We will not reach final conclusions on the way forward for the examination until we have had the chance to consider your response to that letter."
For their part, the councils say they wait until they have received this letter until deciding their response. A statement provided to Planning on behalf of the authorities said that they were "disappointed" by the initial letter, but hinted they would be reluctant to withdraw the plan from the examination, saying they "appreciate [the inspectors] have not yet had the opportunity to hear all of the evidence".
They added: "We are confident that we will be able to provide a substantive response and determine the best way forward. We see the JSP as a vehicle which could deliver an-up-to date plan across the West of England in the shortest possible time."
Withdrawal of the plan could lead to a delay in its adoption of up to five years, according to Simon Fitton, partner at Bristol planning consultancy Alder King. He says: "Any new JSP will have to use the standard method to calculate the housing requirement. But there is also a strong case to say that the plan period should be extended to 2041 to meet the requirements of the NPPF that it should extend to 15 years from adoption. This could have the effect of requiring land for an additional circa 30,000 homes to be identified." In addition, councils could be forced to produce new local plans without reference to the JSP, he says.
However, Simon Prescott, partner at planning consultancy Barton Willmore, says he is hopeful that the issues can be resolved without the plan being withdrawn. He says: "It would be possible to go back and articulate the spatial strategy. Then you could look at the sites needed to deliver that. If they were still appropriate they would stay in the plan, and if not, new sites could be added".
Jobson says that the episode provides a sobering lesson to other areas of the country thinking about preparing JSPs. He says: "Joint plan-making requires authorities to work together and not allow political decision-making to unduly influence what are component parts of a joint strategy."
NOTE: this article was updated at 11am on Tuesday 13 August to make clear that the West of England plan is England's first joint strategic plan rather than a joint spatial plan.