SUMMARIES OF STRATEGY IMPACTS

4.0 INTRODUCTION

4.1 The sustainable development appraisal of the Bath and North East Somerset Local Plan Issues Report was undertaken by a cross-service group of officers throughout November and December 1999. Each strategy is reproduced below followed by a summary of the assessed impacts upon the sustainable development criteria. They summarise the impacts recorded in the matrix of results.

5.0 LIVING AND WORKING STRATEGIES

5.1 Strategy S.1 – "The Local Plan should encourage and retain mixed developments and higher densities in appropriate locations especially in areas highly accessible by means of transport other than the private car. Schemes which enable living and working within the same building and using tele-working may also play a useful role."

5.2 The impacts from this strategy were assessed as largely positive. The emphasis on mixed development and higher densities would consume less land and minerals, include employment uses and support the viability of centres. Facilities would be more accessible, reducing the need to travel, and resulting in beneficial impacts on air quality and energy consumption. The appraisal recommended including references to the potential for combined heat and power in large new developments, the recycling of water, the need to include housing within mixed development and specifying the mix of tenures to increase safety, security and social inclusion.

5.3 Strategy S.2 – "If everyone is to have access to jobs, facilities and housing, we have to ensure that enough land is available for these uses and in the right place. Maps 9, 10 & 11 on pages 38-43 in The Location of New Development Section show sites already identified for development and other possible areas for development."

5.4 The aim of this strategy to provide sufficient land for development to meet economic and social needs resulted in beneficial impacts in related criteria such as health, housing and economy. The emphasis on providing land in the "right place" was viewed as helping to reduce the need to travel and consequently benefiting air quality and energy consumption. It would also mean avoiding areas of landscape and nature conservation interest. It was thought that the term "enough" land was unclear and could imply a large area of land taken for development, which would be harmful to particular criteria. It was recommended that the strategy should specify that the "right place" would indeed be consistent with reducing the need to travel.

5.5 Strategy S.3 – "The Local Plan should specify a target for affordable homes and, in new development, seek an appropriate mix of accommodation in terms of affordability, size and type as this is important in providing balanced communities. The Council already has an objective to provide 600 affordable homes over the next 5 years and is commissioning a ‘Housing Needs Survey’ to gain up to date information on the level and location of need. Encouraging ‘living-over-the-shop’ and bringing empty properties back into use should also make a useful contribution to housing and mixed uses."

5.6 By addressing the need to provide affordable housing and a mix of house types, this strategy was viewed as benefiting criteria on health – providing shelter; housing and employment – helping to diversify the local skills base. Also the encouragement given by the strategy to promoting living over the shop and bringing empty properties back into use, would reduce the need to travel resulting in benefits to air quality, reducing land take and the use of minerals, improving the townscape, supporting town and city centres, and improving safety and security in the centres.

5.7 Strategy S.4 – "New housing should be well related to workplaces, open spaces and services and facilities. There should be greater emphasis on mixed-use environments."

5.8 The strategy’s emphasis on promoting mixed-use development provides similarities with Strategy S1. The impacts were also similar, except there were judged to be no significant impacts on minerals and waste, water quality, land and soil, landscape, nature conservation and built environment. All other impacts were beneficial.

5.9 Strategy S.5 – "The Council has commissioned a detailed study of the local economy in Bath & North East Somerset which will help to identify the location and amount of land required in order to provide for future economic development. This will assist in identifying specific sites. However Maps 9, 10 and 11 identify possible areas for employment land at Bath, Keynsham and Norton-Radstock."

5.10 The commissioning of a study of the local economy by the Council, which will indicate the amount, and location of land required for economic development was viewed as promoting the local economy and therefore having a beneficial impact on this criterion. It was assessed to have no significant impact on the other criteria.

5.11 Strategy S.6 – "In rural areas farm diversification and the re-use of buildings for employment should be encouraged including opportunities for sustainable tourism. In addition policies should enable the expansion of existing businesses and provision of new sites."

5.12 This strategy was viewed as having mixed impacts. Its focus on promoting the rural economy was viewed as having beneficial impacts upon the economy and employment; viability of rural centres; transport (i.e. reducing the need to travel), health (i.e. reducing poverty), landscape (i.e. managing landscapes for tourism), open space (i.e. access to the countryside), and minerals (i.e. re-use of buildings).

5.13 However, it was thought that increases in holiday homes could reduce the availability of local housing. The expansion of businesses and provision of new sites meant the strategy would result in both positive and negative impacts on land and soil (i.e. both new sites and re-use of buildings), nature conservation (i.e. loss of habitats as well as possible opportunities through improved tourism for management of sites).

5.14 It was recommended that the strategy include reference to encouraging development in appropriate locations consistent with reducing the need to travel.

5.15 Strategy S.7 – "Where there is a need and the opportunity, the Local Plan should seek provision of land for recreation, leisure, and community facilities to promote more balanced communities. Standards of open space provision will need to be established."

5.16 The provision of land for recreation, leisure and community facilities, proposed by this strategy, resulted in benefits to health, open space, transport and accessibility and also the economy (i.e. through the employment potential created by leisure facilities and the potential of such provision to increase the general attractiveness of the area thereby attracting business investment). It was also thought that provision might reduce the need to travel, but depending on the type and location of development, could have both positive and negative impacts on the viability of centres and also air quality. It was recommended that provision of facilities should be accessible to the area of identified need in order to reduce the need to travel.

5.17 Strategy S.8 – "The Local Plan should protect existing facilities from changes of use in order to assist in retaining the present level of provision. This includes safeguarding existing employment sites which play an important role in the local economy, protecting existing community facilities and safeguarding open space for both recreational and amenity purposes. Where appropriate, it should encourage more community use of school facilities (dual-use). However, the Local Plan should also allow for flexibility so that appropriate sites can be developed for mixed-use and to allow for change of use where the existing use is no longer suitable."

5.18 The retention of existing facilities where appropriate and the encouragement of dual use of school facilities for other community uses were judged to result in largely positive impacts on most criteria. This was especially the case for the local economy and viability of centres criteria. Also the implication that the retention of existing uses would reduce the need for new building resulted in beneficial impacts on minerals, land, landscape and nature conservation. Redevelopment of sites where the use was unsuitable was viewed as having potential benefits for health and safety criteria.

5.19 Strategy S.9 – "A new retail study will be commissioned to assess the role of the City centre in shopping provision, scope for further change and whether there is a need for other retail development in the City."

5.20 The proposal to carry out a retail study of the City was thought to have potential benefits for the local economy and vitality and viability of centres criteria. Other impacts were assessed to be neutral.

5.21 Strategy S.10 – "The City and the town centres particularly offer most potential for a greater mix of uses. However, the Local Plan should also protect the critical retail function of these centres and enhance the quality and mix of shops. A review of prime shopping frontage, (the most important shopping areas) may be necessary. The Local Plan should also encourage the retention of suburban and village shops although cannot by itself ensure that such shops stay open. The Local Plan also needs to acknowledge the role and impact of Internet shopping."

5.22 The promotion of mixed-uses particularly with the City and Town Centres and the protection and enhancement of the retail functions within them was assessed as benefiting the local economy and viability of centres criteria. It would also benefit transport and accessibility by encouraging the use of public transport, walking and cycling, with consequent positive impacts for air quality and energy use in the transport sector. It was also viewed as benefiting health, and safety and security – the latter by encouraging 24-hour activity in centres. The strategy would also benefit the built environment by promoting viable use of buildings and their conservation.

5.23 Strategy S.11 – "The Council will be working closely with the higher educational establishments and the Universities to assess their future needs."

5.24 This strategy was judged to have no significant impact on any of the criteria.

6.0 ENVIRONMENTAL QUALITY STRATEGIES

6.1 Strategy S.12 – "New development should be located where it makes a positive contribution to the enhancement of the environment and does not cause damage to it and also has economic and social benefits. Where there is overriding need for development in a particular location to meet social or economic priorities, ensure that any adverse impacts on the environment are minimised and compensatory measures sought e.g. enhancing wildlife sites or the landscape elsewhere."

6.2 The proposal to locate development where it would bring economic and social benefits and contribute to the enhancement of the environment was assessed to have largely positive impacts. It was assumed that the reference to ‘the environment’ in the strategy incorporates issues such as air and water quality, landscape and nature conservation, land and soil and the built environment. The strategy was assessed to have beneficial impacts on these criteria.

6.3 Reservations were expressed about the second half of the strategy, which suggests that there could be overriding economic or social needs for development which could adversely affect the environment. It was thought that clarification of the term "overriding need for development" was needed in order to properly appraise this aspect of the policy. It was also thought that the strategy would probably benefit the economy and vitality / viability of centres, but in terms of the economy it was thought that, in the case of restrictive policies arising from the strategy, this could also have a negative impact by turning economic development away.

6.4 Strategy S.13 – "Protect natural resources such as air, water, biodiversity, and soil from harmful development and pollution; ensure natural resources are used in a way which does not endanger the resource, cause pollution or harm amenity; make provision for renewable energy schemes and seek to encourage energy efficiency in new development."

6.5 This strategy is protective of natural resources and was judged beneficial to criteria on minerals and waste, air quality, water quality, land and soil and nature conservation. The provision in the strategy to promote energy efficiency and renewable energy sources also resulted in a positive impact on the energy criterion. The possible savings which energy efficiency could bring to the economy were also recognised. It was thought that one negative impact resulting from the provision for renewable energy would be the impact of such schemes upon the landscape.

6.6 Strategy S.14 – "Safeguard human health and safety in new development, for instance, by avoiding floodplains and requiring treatment of contaminated and unstable land."

6.7 The safeguarding of human health and safety proposed in the strategy was judged as having beneficial impacts on related criteria. The inclusion of the need to avoid developing on flood plains and treating contaminated and unstable land resulted in beneficial impacts on water quality and land and soil. In addition, the protection of flood plains was judged as beneficial to landscape and nature conservation criteria.

6.8 Strategy S.15 – "Promote a hierarchy of waste management policies firstly aimed at minimising waste created, then at re-use of waste materials, then recovery of resources from waste by recycling and recovery of energy and finally through land disposal. Any proposals should minimise impacts on the environment and other land uses."

6.9 The hierarchy of waste management promoted by this strategy was assessed as beneficial to waste, water quality, land and soil and energy criteria (although in the case of energy the potential costs in terms of energy use in recycling was acknowledged). The potential to create business and jobs in waste management and energy recovery was recognised as was the probable reduction in transporting waste. The emphasis on reducing levels of waste in the environment and quantities sent for disposal was also thought to bring possible wider benefits to health and safety and nature conservation criteria.

6.10 Strategy S.16 – "Conserve important mineral resources in the area including Bath stone and fuller’s earth and ensure that where extraction does occur, adverse impacts are minimised and restoration or satisfactory after use is assured."

6.11 The conservation of mineral resources in the District proposed by this strategy was viewed as beneficial to the minerals criterion and also land and soil. The emphasis on restoration and satisfactory after-use of mineral workings was also judged to be beneficial to landscape, nature conservation and probably also safety and security, air and water quality. The restrictions placed upon mineral operators were assessed as being negative in terms of the economy criteria, but balanced by the beneficial impact of restoration and after-use, which could create employment and business.

6.12 Strategy S.17 – "Maintain the protection of statutorily designated sites and areas such as Listed Buildings, Areas of Outstanding Natural Beauty, Conservation Areas, the World Heritage Site, Wildlife Sites and Ancient Monuments."

6.13 This strategy was viewed as benefiting landscape, nature conservation and built environment criteria, in particular, because of its emphasis on the protection of statutorily designated sites, buildings and monuments. It was also thought that because some of these sites are streams and rivers, and relate to land and open spaces, this would benefit water quality, land and soil and open space criteria. Protection of these assets would help maintain a pleasant environment, which would, in turn, promote a sense of well-being and benefit health. The benefits of an attractive environment to the economy and vitality of centres criteria were recognised. However, the restrictions on development and the added costs of Listed Building maintenance resulted in both positive and negative impacts for these criteria.

6.14 Strategy S.18 – "Conserve and enhance local character and distinctiveness as well as locally as locally valued sites, areas and features."

6.15 The conservation and enhancement of local character and distinctiveness was assessed as having similar impacts on the criteria to those for Strategy 17 (i.e. beneficial to environmental criteria including water quality, health and open space; and mixed positive and negative impacts on local economy, and vitality of centres).

6.16 Strategy S.19 – "Identify areas which are in need of visual improvement both in urban and rural locations."

6.17 The benefits of this strategy to landscape, built environment, open space, vitality of centres and local economy were recognised although the latter also included the negative impact of restrictions on, and increased costs for business. The possible negative impact on nature conservation was raised through for example the "tidying" of derelict sites. The appraisal therefore recommended a change to the strategy in terms of visual improvement should not adversely affect nature conservation interests. Also the incorporation in the strategy of a reference to both the natural and built environment was recommended.

6.18 Strategy S.20 – "Set standards for design in new development. Development briefs and other planning guidance can help to achieve this for development of particular sites by showing, density, layout, landscaping and other requirements. Future development should not merely copy existing character but reflect its best aspects and allow for innovation and high quality."

6.19 As this is a fairly non-specific strategy, the assessment of the impacts was uncertain for most criteria and would depend on the detail of particular standards for particular sites. It was agreed however that there would be potential benefits of establishing these issues through development briefs. The stipulation in the strategy that new development should reflect the best aspects of existing character and be of a high standard was recognised as having a beneficial impact on the built environment criterion. However it was recommended that the strategy should specify higher standards of design in new development as well as promoting energy efficiency and water resource management within development briefs. It was also noted that further guidance should draw on and link to the Local Transport Plan.

7.0 ACCESS STRATEGIES

7.1 Strategy S.21 – "Locate new development where there is greatest potential for minimising travel and maximising use of alternative means of transport to the private car. Ensure that the design and layout of new development includes safe, convenient access for pedestrians and cyclists to local facilities and to public transport, including provision for those with impaired mobility. Seek ‘green transport plans’ with development proposals to demonstrate how the proposal will meet sustainable transport objectives."

7.2 The emphasis of this strategy on reducing in the need to travel, through provision for pedestrians, cyclists, and access to public transport within new developments was assessed to have beneficial impacts on transport and energy consumption, also safety and security, health and air quality (i.e. through the promotion of walking and cycling). It would also increase access to facilities such as local employment and open space and enhance local centres through greater access and safety.

7.3 Strategy S.22 – "Include parking standards which discourage car use and support alternative means of transport by limiting car parking provision to maximum levels related to land use, environmental conditions, availability of alternative modes of transport, and location in relation to existing employment, services and facilities."

7.4 Discouraging car use by limiting parking provision where appropriate was judged to have very mixed impacts, which were likely to benefit air quality, energy consumption (i.e. by reducing car use) and the built environment (i.e. by probably reducing the land take for parking and allowing better design solutions). Mixed positive and negative impacts were recorded for transport and accessibility (i.e. limiting parking would encourage accessibility, but limit choice); economy and vitality of centres (i.e. reducing congestion, but the lack of parking would act as a deterrent to business). The importance of ensuring that alternative modes of transport are in place before limiting car parking and of preventing the displacement of parking into residential areas were raised as recommendations for changes to the strategy. The importance of establishing a link between new parking standards the Council’s parking strategy was noted.

7.5 Strategy S.23 – "Provide or improve appropriate recreational facilities in urban fringe areas and other locations easily accessible by public transport to help reduce longer journeys and the need to use cars. In the wider countryside improve the public rights of way network and enhance access to it by providing small scale visitor amenities and introducing traffic management measures to make identified country lanes safer for walking and cycling."

7.6 This strategy deals with three main elements, which were appraised separately:

• The provision of recreation facilities in locations accessible by public transport;
• Improving the public rights of way network and access to it; and
• Introducing traffic management measures in country lanes.

7.7 Beneficial impacts arose for all three elements in terms of accessibility, open space, health and safety, criteria. The first element was viewed as benefiting air quality and energy consumption because of the aim of reducing car use. Both the first and second elements of the strategy were assessed as being beneficial to the economy, and the vitality of centres through the possibility of creating employment related to recreation and provision of visitor centres, as well as increasing trade for local centres and shops in the urban fringe and villages, close to where recreation opportunities are improved.

7.8 Improving the public rights of way network was interpreted by the group as including the physical upgrading of footpaths and byways, which would harm nature conservation interests, while the introduction of traffic calming measures into country lanes was viewed as likely to harm the landscape. It was recommended that safeguards for these interests be included within the strategy. Also that the provision of new facilities in the countryside should ensure that any adverse impact arising as a result of excessive traffic should be avoided.

7.9 Strategy S.24 – "Identify traffic management schemes which give priority to discouraging car use, and promoting road safety, walking, cycling, public transport and environmental improvement. Include traffic calming measures and schemes to re-allocate road space in residential areas, rural settlements, shopping centres, routes to schools and other areas of high pedestrian concentration."

7.10 This strategy was assessed as providing benefits for safety and security, health, air quality and open space (the latter based on the potential of traffic calming to make safer access routes to existing open space and provide opportunities for play space within calmed streets). The strategy was also seen as providing opportunities for enhancing the landscape and the built environment. However, transport and accessibility and energy consumption were assessed as having both positive and negative impacts. Promoting access was viewed beneficially, but reducing car use was limiting choice. Reallocating road space would reduce car use, and therefore save energy, however traffic calming could increase acceleration and braking, therefore increasing energy usage. It was recommended that traffic calming should include providing safety of access to open space and incorporating play space for children.

7.11 Strategy S.25 – "Identify, safeguard and enhance pedestrian and cycle routes that minimise conflicts with motorised traffic and offer attractive safe routes linking communities with local employment areas, shopping areas, community facilities, schools and public transport services."

7.12 Increasing and enhancing safe links to employment and other facilities for pedestrians and cyclists was viewed as resulting in benefits for transport and accessibility, health, safety and security, economy and employment, and vitality of centres. Also possible benefits for air quality and energy consumption were identified if a reduction in car use was encouraged. Possible negative impacts were recorded for landscape and nature conservation and land and soil where land with landscape and/or nature conservation interest could be taken to provide cycle routes. It was proposed that this be avoided by the inclusion of clauses to safeguard these interests.

7.13 Strategy S.26 – "Review existing road proposals. The Council will be carrying out studies to identify which highway improvement schemes should be retained and routes protected."

7.14 This strategy was assessed as having no significant impacts upon the criteria.

7.15 Strategy S.27 – "Protect disused railway lines for recreational uses where they offer opportunity for a linear route including, where appropriate, for recreational railway routes."

7.16 The protection of disused railway routes for recreational purposes was considered beneficial towards improving access to open space, improving health, protecting the built environment (archaeology) and improving transport and accessibility. There would also be possible benefits to the local economy, through the provision of employment, and to the viability of centres by promoting access. However it was considered that increased disturbance along these routes from recreational users might harm nature conservation interests.

8.0 LOCATION OF NEW DEVELOPMENT STRATEGIES

8.1 Strategy S.28 – "The first priority should be to accommodate development for housing, employment and services and facilities within the existing urban area of Bath. In order to fulfil the Structure Plan strategy, full use should be made of existing previously developed land (brownfield sites) consistent with the need to protect and enhance the economic development base of the City, its historic character and open spaces. Proposed sites for development and existing committed sites are shown on Map 9 along with existing allocated sites which need to be reviewed."

8.2 The focus of this strategy on accommodating most development on brownfield sites in Bath, with the aim of protecting and enhancing the economy, character and open spaces in the City, was assessed as benefiting housing, the economy, vitality of the centres, and transport and accessibility. In particular, it was seen as bringing to the City investment in housing and employment, which would increase city centre trade and improve access to facilities, by public transport. The protection of open spaces and steering of development to brownfield sites was viewed as protecting land and soil in the form of greenfield sites and open space and landscape interests, as well as lead to the improvement of derelict sites and therefore benefit the built environment. The impacts on air quality and nature conservation were uncertain as it could reduce the need to travel, but increase congestion within the city, and lead to the loss of nature conservation interests on derelict sites. It was recommended that the strategy should link with the Local Transport Plan objectives for Bath.

8.3 Strategy S.29 – "At Keynsham the Structure Plan indicates that a change to the Green Belt boundary can be made to allow development of new housing and associated development. The Structure Plan places emphasis on changing the Green Belt to meet housing needs but consideration needs to be given to release of land for other uses, including provision of jobs. Map 10 indicates possible areas of search including opportunities at the Cadbury’s site at Somerdale. Also shown are existing committed sites."

8.4 The strategy to locate development at Keynsham was assessed to have beneficial impacts on housing provision, the local economy and the town centre. However, there was an uncertain positive impact on transport as development would increase potential for access by modes other than the car, but it was uncertain whether the need to travel would be reduced by development in this location. The potential to provide accessible open space with the development was acknowledged, but this was balanced against the loss of countryside to development resulting in both positive and negative impacts. A loss of land and soil, landscape character and nature conservation interest was anticipated and resulted in negative impacts for those criteria. It was recommended that the strategy should include reference to the need to look at brownfield sites outside Bath to accommodate development, and there should be a link to the Local Transport Plan objectives for the District’s towns. Impacts on other criteria were uncertain with questionable reductions in car use resulting in better air quality and energy usage.

8.5 Strategy S.30 – "At Norton-Radstock the emphasis should be on providing economic development opportunities to provide for local needs. Beyond existing commitments, only limited further housing provision is envisaged. An area of search for employment land and location of committed sites are shown on Map 11 along with existing allocated sites which need to be reviewed."

8.6 The strategy to provide a better balance between employment and housing in Norton Radstock resulted in beneficial impacts for the local economy and town centres criteria. It was also anticipated that this would reduce the need to travel and improve transport and accessibility with consequent knock-on benefits to air quality, energy consumption and health. The limits on further housing development, but increase in employment were judged to have negative impacts for housing and possibly nature conservation too. The absence of a requirement for open space provision in employment development resulted in a negative input on this criterion, and it was recommended that this be given further consideration. It was also recommended that employment development be focused on brownfield sites; development should not harm nature conservation interests; and there should be a link with the Local Transport Plan for the District’s towns.

8.7 Strategy S.31 – "Outside Bath, Keynsham and Norton-Radstock the suggested strategy is for limited development within or adjoining villages which contributes to the economic and social vitality of rural areas; is appropriate to local character; in the case of residential development is accessible to local facilities and employment; and meets with Green Belt objectives.

In order to secure sustainable patterns of development, one option is to identify clusters of settlements which between them should provide limited development to meet local needs. This may mean concentrating most development at villages which already have a range of local services, can be reasonably accessed from other villages in the cluster and have good public transport connections to major employment areas and other important facilities such as city and town centres (See Map 13). Such clusters and settlements will need to be identified. However, for some villages the most accessible locations for employment and facilities are either Bath, Keynsham or Norton-Radstock.

For employment development the emphasis should be on meeting local needs in order to ensure that provision does not simply attract workers from a wide area leading to additional commuting. Map 12 below shows the existing rural services centres and other large villages which could act as the focal points of clusters."

8.8 This strategy deals with three elements, which were appraised separately:

• Allowing only limited development in villages which supports economic and social vitality;
• Proposal to identify clusters of settlements to accommodate limited development for local needs; and
• Meeting local employment needs in villages.

8.9 The appraisal group thought that there was too much uncertainty surrounding the ‘clusters’ concept to properly appraise its impacts and therefore uncertain impacts were recorded for all criteria for this element.

8.10 The strategy aims to support local facilities and meet local employment needs in villages. It was also thought that this would reduce the need to travel for village residents. The combination of these would be beneficial for transport and access, air quality, energy consumption, health, local economy and vitality of centres.

8.11 It was considered that meeting local employment needs and the need for land to do this would result in possible negative impacts upon land and soil, landscape, nature conservation and housing. The latter was mixed with no significant impact, however it was thought that this strategy could be more restrictive than previous policy towards housing provision in villages. It was recommended that the strategy links with the Local Transport Plan objectives for rural areas.

8.12 Strategy S.32 – "Elsewhere, the District is dotted with hamlets and other small groups of buildings. These are often isolated and have limited access to services. They form part of the open countryside and promotion of development in such locations would be contrary to sustainable development objectives."

8.13 The appraisal group thought that this did not constitute a strategy as written and was instead a statement. If it is the intention of the strategy to prevent development in these locations, then the group considered that this would not necessarily result in a more sustainable option. The Living and Working section of the Issues Report indicates that diversification and re-use of existing buildings may be appropriate. In some of these locations this could support economic and social vitality and be more sustainable. It was recommended that the strategy be amended to state that, whilst general development is not favoured in these locations because it is unsustainable, in appropriate cases it could benefit the vitality of hamlets and reduce the need to travel.

8.14 Strategy S.33 – "Maintain Housing Development Boundaries and extend the policy to include Bath. Detailed boundaries should be proposed in the Local Plan."

8.15 The maintenance of Housing Development Boundaries and their extension to Bath was viewed as containing development within settlements and preventing unrestricted sprawl resulting in possible benefits for land and soil, energy consumption, landscape and nature conservation, so long as HDBs were drawn to exclude land with these interests. It was considered that the vitality of centres could benefit from housing adjacent to them, but could result in development pressure leading to the loss of facilities. This was also applied to open space (i.e. housing pressures could lead to loss of informal open space within the built up area).

8.16 Strategy S.34 – "Strategies 4 and 5 in the Living and Working section show how the Local Plan should provide for new employment uses, but such provision should be at locations which are easily accessible by means other than the car, where possible contribute to mixed use developments and meet environmental concerns. In rural areas this is likely to mean small-scale employment development in and around settlements and limited expansion of existing sites provided it is in scale and character with the area and is consistent with the aim of reducing the need to travel and Green Belt considerations."

8.17 The emphasis of this strategy on mixed use development within and around settlements, where it is accessible by means other than the private car, resulted in beneficial impacts on economy and employment, vitality of centres, transport and accessibility, air quality, energy consumption, health, safety and security and built environment. There was a possible negative impact on land and soil due to the prospect of some land take for development. This also resulted in uncertain impacts on landscape and nature conservation criteria.

8.18 Strategy S.35 – "The Council will be carrying out further research into the existing uses, condition and functions of existing developed sites in the Green Belt to establish the impact of current policies on them."

8.19 The impacts of this strategy were assessed as neutral.

8.20 Strategy S.36 – "The Council suggests a strategy to provide viable and vibrant city and town centres and reduce the need to travel by giving priority to development of retail, office and major recreation and leisure facilities in Bath city centre and Keynsham, Midsomer Norton and Radstock town centres."

8.21 The emphasis of the strategy on providing viable and vibrant centres and reducing the need to travel, resulted in positive impacts for transport and accessibility, the economy and safety and security, and also possibly for air quality, energy consumption and health. It was thought that the strategy could have a significant beneficial impact on those centres mentioned in the strategy, but this was tempered by the possibility of a negative impact on local and village centres by taking investment away from these areas. Depending on sites allocated and the design of development, the impact on open space, landscape, nature conservation and built environment were uncertain.

8.22 Strategy S.37 – "Priority is given to the allocation of brownfield sites which should be developed first taking account of any nature conservation interest or landscape value."

8.23 The focus of this strategy on the use of brownfield sites resulted in a beneficial impact on conserving land and soil, housing, local economy and minerals and waste. The re-use of brownfield sites might result in decontamination of sites and benefits to water quality, health, and safety and security. Impacts on open space, landscape, nature conservation and built environment were uncertain. It was noted that the development of brownfield sites may not always be appropriate, for example sites in isolated rural locations would be unlikely to help reduce the need to travel.