3.7 As set out above the Partial Update cannot amend the spatial strategy of the Core Strategy. Therefore, the existing spatial strategy must be the basis for identifying and allocating sites for delivering additional housing. The existing spatial strategy directs development to the most sustainable locations in the District, minimising the need to travel especially by car and restrains growth in less sustainable locations likely to generate increased travel by private car, including villages. In line with the climate emergency the strategy helps to also ensure carbon emissions from transport are minimised. The Core Strategy also seeks to ensure that housing provision is aligned with infrastructure.
3.8 The Core Strategy prioritises the redevelopment of brownfield sites for housing within the urban areas, and especially within Bath as the main centre in the District offering employment opportunities, an excellent range of services and facilities and relatively high levels of sustainable transport use. Keynsham is the next most sustainable location for accommodating housing within the District, given it is well linked to Bath through sustainable means of transport, including by train and a good bus service, and it has good services and facilities and an improving employment base. Opportunities for housing are then focussed towards the other towns within the District (Midsomer Norton, Radstock and Westfield Parish).
3.9 The adopted Core Strategy also directed some housing development of around 50 dwellings, primarily aimed at meeting local needs, towards the larger and more sustainable villages (i.e. those with a greater range of services and facilities and better public transport accessibility to the main centres in B&NES). Within the Core Strategy a more limited scale of development of around 10 to15 dwellings is provided for at the smaller villages outside the Green Belt. The Core Strategy also directed a more strategic level of growth to Whitchurch given its comparative sustainability in terms of links to job opportunities and services & facilities in Bristol. It is not considered appropriate to focus further strategic growth at Whitchurch in this partial update for the reasons outlined below and because its close relationship with Bristol means it is better considered through the WECA Spatial Development Strategy.
3.10 In distributing housing growth the role of the Green Belt must also be taken into account. Some of the most sustainable settlements within B&NES, most notably Bath and Keynsham, are tightly surrounded by the Green Belt. Therefore, the amount of development provided on sites adjoining these settlements is more limited than otherwise would be the case. Land can only be removed from the Green Belt for development where this can be justified by exceptional circumstances. Some land was removed from the Green Belt in the Core Strategy and allocated for housing development adjoining Bath, Keynsham and Whitchurch (the latter being more sustainably linked to Bristol rather than centres within B&NES).
3.11 At a strategic level, opportunities on the edge of Bath were assessed and allocated where appropriate through preparing the Core Strategy. The impact of development on the edge of the City not only in Green Belt terms, but on the World Heritage Site and its setting, the Cotswolds AONB and other environmental assets, was shown to limit development potential. Circumstances are not considered to have changed since adoption of these Development Plan Documents.
3.12 At Keynsham land well related to the Bristol-Bath public transport corridor has already been removed from the Green Belt on the eastern side of the town. Some of this land was allocated for housing and employment development in the Core Strategy and is currently being developed. The remainder of the land was safeguarded for future development pending review of the Core Strategy and its deliverability. This review is now being undertaken through this partial update of the Local Plan. Therefore, as set out below and subject to evidence on its deliverability there is the opportunity to allocate this land for development now (see section 3 below).
3.13 The supply shortfall of around 1,200 dwellings therefore, needs to be addressed in accordance with the spatial strategy outlined above. Since the adoption of the Core Strategy and the Placemaking Plan the NPPF has been amended. These amendments change the emphasis regarding and indicate a greater level of protection for the Green Belt and this needs to be reflected in identifying the solutions to the supply shortfall. As set out below brownfield sites have been identified capable of delivering around 1,000 dwellings during the plan period. Greenfield sites, not in the Green Belt, in sustainable locations then need to be considered. No greenfield opportunities outside the Green Belt on the edge of Bath have been identified. The safeguarded land on the edge of Keynsham is no longer within the Green Belt and is in the next most sustainable location in the District. Subject to evidence the safeguarded land can deliver around 300 dwellings during the plan period. As such the brownfield sites and safeguarded land east of Keynsham are capable of meeting the overall supply shortfall with a degree of flexibility.
3.14 However, if the safeguarded land at Keynsham is not deliverable the Council will need to consider what measures would be required to facilitate its delivery. As set out in more detail below transport infrastructure measures might be needed that require removal of additional land from the Green Belt to the north of the A4. In the circumstances where the safeguarded land is not deliverable without such intervention the Council will need to carefully consider alternative solutions, including greenfield sites to the south of the District and outside the Green Belt, if those are demonstrated to be sufficiently sustainable, as well as smaller, non-strategic greenfield sites on the edge of Bath within the Green Belt.
3.15 As required by the NPPF, para 138, the Council will need to consider the sustainability implications of the different options and of channelling development towards locations beyond the Green Belt outer boundary. As such a balanced judgement will need to be made regarding the comparative sustainability and benefits of these different solutions against the harm caused to the Green Belt, as well as other harm. This balanced judgement will determine whether exceptional circumstances exist to remove further land from the Green Belt.