Please see this update from North Somerset Council.

We are writing to update you on the recycling centre booking system which was initially planned for introduction this autumn.

Given the significant changes to the recycling and waste service this year, the decision was made to delay the introduction until early next year. We can now confirm that Weston-super-Mare will be the first site to benefit from the system. From Monday 2 February, you’ll need to book a slot before visiting.

From Monday 2 March, the same system will be in place for the Portishead and Backwell sites.

For residents with vehicle permits, we will be contacting them before the new system starts to explain how permits will work with the changes.

The booking system will be on the website and accessible via the North Somerset Council app.

For those without access to the internet, we ask residents to help to make a booking online on behalf of friends and family members. Doing it online is the quickest, easiest and cheapest way to book. Calls into the contact centre will be answered with an automated system to capture the information that we need for the booking.

Please share this wherever possible to make residents aware of this change.

More details including frequently asked questions are available on the website.

This response has been approved by the majority of the Parish Council and reflects:

• the clear views expressed by residents at our drop-in session on 9 December 2025 
• the policies and evidence in our made Neighbourhood Plan 2020-2036 (adopted after an 81 % “yes” vote in the 2021 referendum)
• technical evidence including Defra MAGIC maps, the council’s own Infrastructure Delivery Plan and the government’s new Environmental Improvement Plan 2025

Summary of the Parish Council position

Our Neighbourhood Plan already sets out how this parish should grow: modest, small-scale development that meets genuine local needs while protecting Green Belt, landscape, heritage, ancient woodland and the rural character of the village.

Residents accept that some new homes are needed, but they overwhelmingly oppose the sudden imposition of 1,100 houses in five huge Green Belt sites under Policy LP4.

The scale, location and lack of infrastructure for these proposals are completely at odds with our Neighbourhood Plan and with national planning policy. We therefore ask that Policy LP4 is deleted in full.

Full formal representation (as submitted to North Somerset Council) SEE BELOW

 

Why this matters to our community

Our Neighbourhood Plan was written by local people, consulted on extensively and approved by 81 % of voters who turned out in 2021. It deliberately limits new housing to around 150–200 homes across the whole plan period so that growth remains sustainable and the village keeps its identity.

Policy LP4 would override that democratic decision without any proper justification or consultation.

We are not against all development – many residents said they would support 20–30 well-designed homes on less sensitive sites – but we are united against the irreversible damage these five large Green Belt allocations would cause.

The full response below explains the detailed planning reasons why Policy LP4 is unsound.

 

What you can do

The consultation closes at 5 pm on Friday 12 December 2025.

We encourage every resident to submit their own views (even a short email) to planning.policy@n-somerset.gov.uk quoting “Policy LP4” in the subject line.

Important tip: The online form can time out if you’re not careful – residents have reported this. Always write your full response in a separate document first (e.g., Word or Notes), then cut and paste it into the form. Note – you can go in and amend your submission afterwards up to the closing time.

Every comment you make will use the same two main boxes:

• “If you consider the North Somerset Local Plan 2041: Pre-submission Plan is not sound, not legally compliant or not in compliance with the Duty to Cooperate then please provide details. Please be as precise as possible.”
  (This is where you write your own facts/feelings. Be specific: e.g., “This destroys ancient woodland with no buffer” or “Traffic will double our village overnight.”)
• “Please set out any modifications you consider necessary to make the North Somerset Local Plan 2041: Pre-submission Plan legally compliant and sound in respect of any issues you have identified.”
  (Suggest fixes: e.g., “Delete LP4 and limit to small homes on non-Green Belt sites” or “Pause for flood checks.”)

Your comment doesn’t have to match the Parish Council’s – it’s your voice that counts.

 

You can also comment on related chapters like SP7 (Green Belt), LP9 (Green Belt extent), or the individual sites in Schedule 1.

 

Thank you for your support.

Pill & Easton-in-Gordano ParishCouncil

 

Pill & Easton-in-Gordano Parish Council

Formal Response to North Somerset Local Plan 2041 – Policy LP4

Submitted 11 December 2025

 

Policy LP4: Strategic location – Pill and Easton-in-Gordano

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Pill & Easton-in-Gordano Parish Council objects to Policy LP4. Designating our parish as a fourth Strategic Development Location for ~1,100 dwellings on five Green Belt sites is unsound, unlawful and undeliverable. This allocation only appeared in June 2025 – it was absent from the July 2024 draft – and has not been properly evidenced or consulted on. This abrupt June 2025 elevation misrepresents the February–March 2025 consultation, which sought views only on individual sites as ‘potential allocations’ in sustainable villages, not as a strategic location (Consultation Paper Section 5.43). Cabinet’s 18 June claim of ‘general support’ (para 3.21) ignores localised objections and the fact no strategic question was asked, breaching Localism Act 2011 engagement duties.

 

• Not Positively Prepared – Forces a Category A village (1.9 % of North Somerset’s electorate) to take 4.6 % of all new housing, overriding our made Neighbourhood Plan (81 % referendum support, 2021) which caps growth at 150–200 homes to 2038. Policy LP4 is also procedurally flawed and unjustified because it was introduced as a complete surprise in June 2025 – absent from all previous consultations. The supporting evidence is extraordinarily sparse: no updated Sustainability Appraisal, no transport modelling, no habitat surveys, and no landowner agreements for the proposed active travel routes. Several of these routes (notably the Markham Brook overbridge and connections across private land) appear to have been drawn freehand on a map with no regard to topography, ancient woodland, floodplain, or existing rights of way. This gives the clear impression of a rushed, last-minute insertion to plug a perceived housing numbers gap, rather than a properly prepared, evidence-led allocation. Such an approach renders the policy neither justified nor effective and risks the entire Plan being found unsound.
• Not Justified – The Sustainability Appraisal fails to use Defra MAGIC maps, missing floodplain woodland (Flood Zones 2/3), ancient woodland and priority habitats. No objective assessment of non-Green Belt or brownfield alternatives has been carried out (NPPF para 157). The proposed Markham Brook active travel route cuts through irreplaceable ancient woodland with no 15 m buffer or compensation strategy (NPPF para 193c; Natural England Standing Advice 2024). The Sustainability Appraisal and evidence base contain no assessment of the loss of best and most versatile agricultural land. Four of the five LP4 sites (HE2015 Pill Green, HE20491 Lodway Farm, HE206 Gordano Services, and HE20492 Pill Road) are predominantly Grade 1 and Grade 2 according to Defra’s Provisional Agricultural Land Classification (see attached screenshot from magic.defra.gov.uk). This is prime farmland that the NPPF (para 119 and Planning Practice Guidance) says should only be developed as a last resort after all reasonable lower-grade alternatives have been exhausted. No such alternatives assessment has been carried out, rendering Policy LP4 not justified (NPPF para 36(b)).
• Not Effective – The council’s own Infrastructure Delivery Plan (Oct 2025, §8.3) labels M5 Junction 19 upgrades and Pill flood-risk management as high-risk and unfunded. The five LP4 sites together would add approximately 1,540 peak-hour car trips (1.4 cars/home × 1,100 dwellings) – on top of Portishead’s remaining growth and the continuing expansion of Royal Portbury Dock HGV traffic – with no evidenced mitigation and no funded solution. National Highways has raised unresolved objections to the cumulative impact on Junction 19 capacity and safety. In the absence of any robust assessment or deliverable mitigation, Policy LP4 fails the effectiveness test (NPPF para 36(c)) and would cause severe residual cumulative impacts on the strategic road network (NPPF para 116). Flood mitigation fails the sequential test (NPPF para 174).
• Inconsistent with National Policy & Legally Non-Compliant – Directly breaches NPPF paragraph 148: the council has published no evidence that brownfield opportunities and urban density increases have been maximised before releasing high-value Green Belt in Pill. Residents and the parish council are aware of potential brownfield sites that have not been fully explored. Releasing these five Green Belt sites therefore fails the sequential test, the “grey belt” priority, and the requirement for exceptional circumstances. This, combined with tiny consultation responses (often <30 per site) and a developer-led process, also breaches the Localism Act 2011.
• Duty to Cooperate failed – No updated Statements of Common Ground with National Highways, Natural England or the Environment Agency on J19, habitats or SuDS.

This policy risks the whole plan being found unsound (as happened with the Joint Spatial Plan in 2020).

 

Modifications required

Delete Policy LP4 in its entirety and remove all five Pill & Easton-in-Gordano sites from the proposals map. 

Revert to the July 2024 spatial strategy under which our parish was not a Strategic Location and growth was limited to local needs only, in line with Policy SP3 and our Neighbourhood Plan.

 

Furthermore, the Plan’s failure to examine the government’s new Environmental Improvement Plan 2025 (EIP 2025, published 1 December 2025) renders LP4 unsound and non-compliant. EIP sets binding national targets under the Environment Act 2021, including 30% land protection by 2030 (30by30), mandatory 10% Biodiversity Net Gain (BNG) for all developments by mid-2026, and £10.5bn for nature-based flood defences (protecting floodplain woodlands like those on Pill Green HE2015). It requires Local Nature Recovery Strategies (LNRS) by end-2025, which local plans must integrate for habitat mapping, no-net-loss of ancient woodland (via updated inventories by 2027), and riparian buffers along Markham Brook.

NSC’s June 2025 allocation predates EIP and lacks any assessment of these requirements—no BNG strategy for irreplaceable habitats (NPPF para 193c alignment), no LNRS-informed alternatives to Green Belt release, and no evidence of flood-resilient designs (e.g., SuDS to avoid downstream risks in Pill village). This breaches NPPF para 36 (not justified/effective) and the Biodiversity Duty for public bodies.

 

**To comply, pause submission until: (i) Full EIP/LNRS integration via revised Sustainability Appraisal; (ii) Independent audit of sites against EIP targets (e.g., 250,000 ha habitat creation by 2030); and (iii) 6-week extended consultation. Additionally, fund a Parish-led audit of small/micro-sites (2–5 homes each) on underused/brownfield land within the parish, as reasonable alternatives prioritised under NPPF paras 36(b), 69, 119 and 148. Residents have identified potential infills fitting local needs without Green Belt harm—exploring these first would demonstrate proportionate evidence and effective rural land use. 

 

These fixes would enable evidence-led, nature-positive growth without judicial review risks.

 

Wish to appear at hearing? Yes – to represent 4,200 residents directly affected, with a 2,000+ signature petition and unique local evidence (MAGIC maps, flooding photos, daily traffic experience). We need to question the council, National Highways and Natural England in person about the missing traffic modelling, unfunded J19 upgrades and ancient woodland destruction so the Inspector gets the full picture and can recommend deletion of Policy LP4.

 

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

LP9 – Extent of the Green Belt

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Pill & Easton-in-Gordano Parish Council objects to Policy LP9 because it removes five large areas of Green Belt around our parish to enable Policy LP4 (1,100 homes). This deletion is unsound for the following reasons:

• Not justified & inconsistent with national policy (NPPF paragraphs 142–148):
  The council has not demonstrated the “exceptional circumstances” required to alter Green Belt boundaries, nor has it shown that all non-Green Belt alternatives have been fully explored and exhausted. No evidence has been published to prove these sites are “grey belt” (lower-value Green Belt). In fact, the sites contain high-value features: ancient woodland edges, priority habitats, floodplain woodland, and land identified on Defra MAGIC maps as irreplaceable.
• Not positively prepared:
  The sudden decision in June 2025 to treat Pill as a fourth “strategic location” (the same status as the three main towns) was never part of the July 2024 draft. This late change has not been tested through proper alternatives assessment.
• Not effective:
  The supporting Infrastructure Delivery Plan (Oct 2025, section 8) labels essential road and flood defences as “high risk” and unfunded. Green Belt removal is therefore premature.
• Legal compliance & Duty to Cooperate:
  No updated Statement of Common Ground with neighbouring authorities (e.g., Bristol City or National Highways) shows how the cumulative impact on Junction 19 has been resolved.
• LP9’s proposed Green Belt boundary amendments for Pill LP4 sites are unjustified and inconsistent with NPPF para 147, lacking evidence of maximised brownfield/urban options first. Sites HE206 (Land East of Gordano Services) and HE20491 (Lodway Farm) form the critical remaining Green Belt corridor between Pill parish and Royal Portbury Dock, essential to prevent coalescence and sprawl. NSC’s own Portishead assessment confirms: “The remaining Green Belt land located between the port estate and Portishead is considered extremely sensitive in preventing coalescence and checking unrestricted urban sprawl.” Deleting this gap now (while protecting similar ones elsewhere) is arbitrary, with no grey belt assessment (para 148) or habitat compensation (para 193a/c). This rushed June 2025 change breaches Localism Act 2011; Duty unmet without cross-boundary input from National Highways on dock-adjacent sprawl.

Modifications required

Delete the proposed Green Belt deletions around Pill & Easton-in-Gordano from the LP9 Policies Map and retain the existing Green Belt boundary.

Alternatively, if any change is to be considered, the council must first publish a full Green Belt Review proving exceptional circumstances and that these sites are genuinely low-value “grey belt” after all brownfield and non-Green Belt options have been used up. Retain current Green Belt boundaries for HE206/HE20491; revert LP9 amendments to July 2024 draft. Mandate strategic gap designation for Pill-Dock corridor, per LP14 principles.

 

Wish to appear at hearing? Yes – We represent the community most directly affected. We have local evidence (flood photos, traffic records, MAGIC map extracts) that the council has not properly considered. We need to be able to question officers and cross-examine statutory consultees (Natural England, National Highways) in person to ensure the Inspector gets the full picture.

 

LP11: Transport infrastructure, allocations and safeguarding

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Policy LP11 is unsound (not justified, not effective, and not consistent with national policy) because:

The proposed “active travel route” across Markham Brook (shown on the Policies Map and listed in Schedule 7) would cut straight through irreplaceable ancient woodland and priority habitat deciduous woodland in the Gordano Valley.

→ Natural England’s Standing Advice (2024) and NPPF paragraph 193c require a minimum 15-metre untouched buffer on each side of ancient woodland. The government’s Environmental Improvement Plan 2025 (published 1 December 2025) reinforces this by committing to maintain protections for ancient woodland as irreplaceable habitats and evolve Biodiversity Net Gain to ensure infrastructure like active travel routes delivers net environmental benefits without harm. No layout has ever been produced that can meet this requirement. The route is therefore physically undeliverable without destroying habitat that national policy says must not be lost unless there are “wholly exceptional reasons” and full compensation – neither of which exist here.

The Sustainability Appraisal and the rest of the evidence base contain no assessment whatsoever of this route’s impact on ancient woodland, priority habitats, protected species (e.g. bats), or the legal need for buffers. This makes the policy not justified (NPPF para 36b).

No alternative alignments appear to have been examined. The council has not demonstrated that a deliverable route is possible at all – making the policy not effective.

The proposed Markham Brook active travel bridge and path would destroy irreplaceable ancient woodland and priority habitat with no 15 m buffer and no compensation strategy. This directly breaches NPPF paragraphs 193c and 192 and renders the policy unsound.

 

This same route is being relied on to “mitigate” the traffic impact of the 1,100 homes proposed under Policy LP4. If the route cannot be built, the mitigation fails and the housing allocation becomes even less deliverable.

 

Modifications required

Delete the Markham Brook active travel route from Policy LP11, Schedule 7, and the Policies Map, or redraw it so that it demonstrably avoids all ancient woodland and priority habitat with the required 15 m buffers (Natural England Standing Advice 2024). Align with Environmental Improvement Plan 2025 commitments by requiring a Biodiversity Net Gain assessment (at least 10%) and integration with Local Nature Recovery Strategies to prove no net habitat loss.

If no deliverable alternative exists, the council must remove the reliance on this route as mitigation for the Pill & Easton-in-Gordano strategic location (Policy LP4) and reassess the housing numbers accordingly. Reroute the Markham Brook link to avoid private land and existing bridleway PE2/1, or delete it entirely pending full landowner consultation.

 

Wish to appear at hearing? Yes – Pill & Easton-in-Gordano Parish Council has direct local evidence (site photos, MAGIC map extracts, resident records) showing that the proposed route crosses ancient woodland that the council’s own evidence appears to have missed. We need to be able to question council officers and Natural England in person so the Inspector can see for himself/herself that the route is undeliverable and the policy is unsound.

 

LP14: Royal Portbury Dock

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Policy LP14 is unsound and inconsistent with national policy because it directly contradicts its own wording and objectives when applied to the proposed Strategic Location at Pill & Easton-in-Gordano (Policy LP4 – 1,100 new homes).

• LP14 states that new development must not cause unacceptable harm to the operation, access or expansion of Royal Portbury Dock.
• It also requires improvements to M5 Junction 19 and local roads to be delivered in advance of development that would otherwise harm the port.

The 1,100 homes in Pill would add approximately 700 extra peak-hour car trips straight onto the A369 and Junction 19 – the only realistic route for dock traffic, including hundreds of HGVs and abnormal-load vehicles that must use the slow lane on the Avonmouth Bridge.

The council’s own Infrastructure Delivery Plan (Oct 2025, section 8.3) classifies Junction 19 upgrades as high risk and unfunded, with no committed scheme or funding before 2030.

No cumulative traffic modelling of the combined impact of Pill homes, Portishead growth and ongoing port expansion (Bristol Port Master Plan 2023) has been carried out, contrary to the requirement for a robust transport evidence base (NPPF paragraph 118).

This means Policy LP4 would cause exactly the unacceptable harm that LP14 is supposed to prevent, and the required road improvements are not in place and cannot be guaranteed.

The two policies therefore directly contradict each other, making the plan ineffective, unjustified and inconsistent with national policy.

 

Modifications required

Delete or heavily amend Policy LP4 so that no housing growth that relies on Junction 19 is permitted until the necessary upgrades are fully funded and built.

Alternatively, remove Pill & Easton-in-Gordano as a Strategic Location entirely, reverting to the July 2024 strategy, so that LP14 can be properly applied without contradiction.

Amend Policy LP14: Portbury dock with the addition of “The remaining Green Belt land located between the port estate and Pill and Easton-in-Gordano is considered extremely sensitive in preventing coalescence and checking unrestricted urban sprawl

 

Wish to appear at hearing? Yes – We need to speak at the hearings because we live next to the dock and use Junction 19 and the A369 every day. We can give the Inspector first-hand evidence of current congestion, photos of queuing HGVs, and local knowledge of how quickly the system grinds to a halt. We also want to question the council and National Highways on why no proper cumulative traffic modelling has been done and how they can claim LP14 is being followed when it clearly isn’t.

 

SP3: Spatial strategy

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Pill & Easton-in-Gordano Parish Council objects to Policy SP3.

Policy SP3 is unsound because it jumps Pill (a Category A village) to full strategic-location status without any prior consultation. The February–March 2025 consultation paper framed the sites only as non-strategic “other potential” village-scale allocations (Table 7.1). No question was ever asked about elevating the parish to a fourth strategic location. Yet the Cabinet report of 18 June 2025 (paras 3.20–3.21) cited “general support for the principle of development” to justify the change, misrepresenting responses that were never sought on strategic status. This arbitrary breach of the spatial hierarchy (NPPF para 36b) overrides our made Neighbourhood Plan without evidence and renders the policy unjustified.

 

Not Positively Prepared (NPPF para 36a): SP3 fails to proactively meet needs through collaboration, sidelining village-scale alternatives and imposing disproportionate growth (55% stock increase) without addressing unmitigable harms like flood exacerbation.

Not Justified (NPPF para 36b): Evidence lacks robustness; Sustainability Appraisal overlooks Defra MAGIC constraints (e.g., floodplain woodland in Zones 2/3 at Pill Green). No proportionate alternatives assessment justifies bypassing the hierarchy for Green Belt release over brownfield/urban options (NPPF para 148).

Not Effective (NPPF para 36c): Undeliverable: Draft IDP (Feb 2025, §8.3) flags high-risk, unfunded infrastructure (J19 upgrades). Cumulative ~700 peak trips from Pill, plus Portishead/dock growth, lack modelling (NPPF para 116 and 118), breaching SP3’s own flood minimisation.

Inconsistent with National Policy (NPPF para 36d): Violates spatial principles (NPPF para 74: Neighbourhood Plan conformity) and Green Belt protections. Legally non-compliant with Localism Act 2011 (developer-led over community needs). Duty to Cooperate unmet: No updated Statements of Common Ground on cross-boundary J19/ecology impacts (e.g., with Bristol/National Highways).

This flawed strategy risks Plan-wide unsoundness, reverting to outdated policies and developer speculation.

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

Modifications required

To make SP3 sound and compliant, we request:

1. Revise SP3 Hierarchy: Explicitly limit strategic growth to the three main towns; revert Pill to Category A village status, aligning with “local needs” only (NPPF para 74). Remove cross-references to LP4.
2. Strengthen Evidence Base: Commission independent hierarchy review: Assess non-Green Belt alternatives via MAGIC-integrated SA; include 10-year J19 modelling (cumulative impacts) and NE/EA responses on flood/habitats.
3. Pause and Extend Consultation: Halt until Statements of Common Ground (NPPF para 28) evidence Duty to Cooperate (e.g., Bristol transport).
4. Enhance Safeguards: Revise SP3 to require infrastructure delivery before growth (e.g., J19 upgrades pre-occupation).

These modifications ensure SP3 is positively prepared (community-aligned), justified (evidenced alternatives), effective (deliverable), and NPPF-consistent—avoiding Examination rejection.

 

Wish to appear at hearing? Yes – PEIG PC seeks participation to represent our community’s consensus on SP3’s hierarchy flaws, risking Plan failure and speculation. As a directly impacted village with a made Neighbourhood Plan, we offer unique evidence (MAGIC data, local flood/traffic records) on unaddressed issues (e.g., J19 overload breaching spatial limits). Hearings allow testing NSC’s responses on evidence gaps (SA alternatives; Duty to Cooperate), cross-examining consultees (NE/Highways), and discussing modifications (e.g., hierarchy reversion). This ensures balanced, local input, upholding NPPF para 74 and preventing appeals that undermine our Plan. Non-participation disadvantages our 4,200 residents in a developer-dominated process.

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

SP7: Green Belt

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Pill & Easton-in-Gordano Parish Council objects to Policy SP7 (Green Belt).

This policy is unsound because it allows the release of five high-quality Green Belt sites around our village (total ~1,100 homes) without meeting any of the strict national tests in the NPPF (December 2024).

• It has not shown that all non-Green Belt options (brownfield sites, higher density in towns) have been used up first.
• It has not demonstrated that these five sites are low-value “grey belt” – in fact they include ancient woodland edges, priority habitats, floodplain and woodland.
• There is no published Green Belt review or exceptional-circumstances report that justifies taking this land out of the Green Belt.
• Policy SP7 is unsound and inconsistent with NPPF para 145, as it fails to demonstrate “exceptional circumstances” for Green Belt release in Pill & Easton-in-Gordano. Two LP4 sites (HE206 and HE20491) constitute the remaining narrow Green Belt corridor between the parish and Royal Portbury Dock, vital for preventing coalescence and urban sprawl. Yet when assessing Portbury Dock, NSC stated: “The remaining Green Belt land located between the port estate and Portishead is considered extremely sensitive in preventing coalescence and checking unrestricted urban sprawl” (This consultation within section “4 Locational Policies” – “Policy LP14: Royal Portbury Dock”). Allocating these sites now contradicts this, prioritising development over high-value Green Belt without grey belt proof or alternatives assessment. This developer-led approach breaches Localism Act 2011; Duty to Cooperate unmet with no joint work on landscape gaps (e.g., with Bristol on port impacts).
• It fails para 148 by releasing Pill’s sensitive corridor (HE206/HE20491) without proving alternatives, misusing Feb responses that objected to Green Belt loss. Cabinet’s ‘well supported’ claim (3.21) ignores this, no strategic consult occurred, making boundary changes unjustified and inconsistent with Portishead’s ‘extremely sensitive’ protection (LP14)

 

This sudden change only appeared in June 2025 – it was not in the July 2024 draft. It looks rushed and reactive rather than properly planned.

Releasing this Green Belt without the proper evidence breaks national policy and makes the whole plan unsound.

 

Modifications required

1. Delete the proposed Green Belt deletions around Pill & Easton-in-Gordano (the five sites in Policy LP4).
2. Amend SP7 to explicitly protect Pill-Dock Green Belt corridors as strategic gaps to prevent merger/coalescence (per NPPF para 143(b)), deleting LP4 sites HE206/HE20491. Require full alternatives appraisal before any release (para 148).
3. Keep the Green Belt boundary exactly as it is now, or at the very least only allow removal if a proper, published Green Belt review proves exceptional circumstances and shows the land is genuine low-value “grey belt”.
4. Add wording to SP7 that says: “Green Belt release will only happen after all reasonable non-Green Belt alternatives have been exhausted and a full exceptional-circumstances report has been published and consulted on.”

These changes would bring the policy back into line with national rules and stop our high-quality countryside being lost without proper justification.

 

Wish to appear at hearing? Yes – we need to speak at the hearings because we are the community most directly affected by the proposed Green Belt loss. We have local evidence (photos, flood records, MAGIC map extracts, 2,000+ petition signatures) that the council appears to have ignored. We want to question council officers in person about why no proper Green Belt review was done and why they think these sites meet the tough new “grey belt” tests. Only by speaking directly can we make sure the Inspector hears the real village view, not just the council’s or developers’ version.To cross-examine NSC on self-contradictory evidence re: sensitive corridors, ensuring Inspector sees the coalescence risk.

 

SP10: Transport

 

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

Policy SP10 is unsound, ineffective and inconsistent with national policy (NPPF para 109) because the transport evidence for the 1,100-home Pill allocation (LP4) is extraordinarily sparse and demonstrably inadequate (see also para 118 on required assessments).

• The council’s own Infrastructure Delivery Plan (October 2025, section 8.3) classifies M5 Junction 19 upgrades as “high risk” with no funding or delivery plan.
• No cumulative 10-year traffic modelling has been carried out for the combined impact of Pill (≈ 700 peak-hour car trips), Portishead growth, and expanding Royal Portbury Dock traffic.
• The active travel routes shown on the Policies Map – notably the Markham Brook overbridge and connections across private land – appear to have been drawn freehand without site visits, surveys or landowner agreements. They cut directly through ancient woodland, floodplain woodland and private property, ignoring the mandatory 15-metre buffer (Natural England Standing Advice) and basic topography.

These routes are undeliverable and give every impression of a rushed, last-minute insertion to justify a housing numbers gap rather than a properly prepared, evidence-led strategy. SP10’s requirement to “minimise adverse effects” on the highway network and the environment is therefore meaningless for Pill. The policy fails on the council’s own evidence.

 

Modifications required

To make SP10 sound and deliverable it must be amended to state:

“No development at the Pill & Easton-in-Gordano Strategic Location (Policy LP4) shall commence until M5 Junction 19 capacity improvements are completed, funded and open to traffic.”

And

“The safeguarded active travel route across Markham Brook (Schedule 7) shall be deleted or re-routed to avoid all ancient woodland and its 15-metre buffer zone.”

Without these changes SP10 is ineffective and the Plan risks being found unsound.

Wish to appear at hearing? Yes – We live with the daily traffic chaos on the A369 and at Junction 19. We have photographs, dash-cam footage, and local knowledge that the council’s reports have missed. The Inspector needs to hear directly from people who will suffer the gridlock if this policy goes ahead unchanged.

 

SITE SPECIFIC RESPONSES

 

Land at Lodway Farm (HE20491) 

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons
The Parish Council objects to allocating Land at Lodway Farm (HE20491) for 160 dwellings under LP4. Residents at our 9 Dec drop-in recognise the need for some new homes but oppose huge estates—most would accept 20–30 here if fitting the awkward access (The Breaches/Beechwood Rd) and preserving the Green Belt buffer to the estuary, aligning with our Neighbourhood Plan’s local-scale growth. This allocation is undeliverable and harms rural character without “very special circumstances”.

• Not Positively Prepared – The 160-home scale overrides our 150–200 cap (81% support 2021), ignoring modest alternatives.
• Not Justified – No noise modelling for M5 or heritage assessment (Grade II* Church of St George views). Green Belt not “grey” (NPPF para 148).The Sustainability Appraisal contains no assessment of the loss of best and most versatile agricultural land. The site is predominantly Grade 1 (excellent quality) with the remainder Grade 2 according to Defra’s Provisional Agricultural Land Classification (see attached screenshot from magic.defra.gov.uk). This is the highest-quality farmland that the NPPF (para 119 and Planning Practice Guidance) says should only be developed as an absolute last resort after all reasonable lower-grade alternatives have been exhausted. No such alternatives assessment has been carried out, rendering the allocation not justified (NPPF para 36(b)).
• Not Effective – IDP Oct 2025 (§8.3) flags unfunded J19; ~224 vehicles overload Marsh Lane without modelling (NPPF para 115d). Active travel (River Avon Trail) unfeasible on third-party land.
• Inconsistent/Legally Non-Compliant – Breaches NPPF para 148 and paras 106-108; Duty unmet with Historic England.

Modifications required

Delete from Schedule 1; revert to July 2024 non-strategic status, capping at local needs (20–30 homes max, with buffer).

 

Wish to appear at hearing? Yes – To represent consensus on modest scale vs. estate overreach.

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

Land East of Gordano Services (HE206) 

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons
The Parish Council objects to Land East of Gordano Services (HE206) for 200 dwellings under LP4. Residents wouldn’t mind a few homes here but see ~186 (original proposal) as creating a standalone “village” disconnected from Pill, with insurmountable traffic safety on Marsh Lane (no access allowed). Undeliverable due to consultee objections on flooding/highways, and undeliverable in this number due to severe infrastructure constraints

• Not Positively Prepared – Disproportionate scale ignores community preference for small infill, overriding Neighbourhood Plan cap. No parish collaboration on alternatives, ignoring cumulative dock expansion impacts (Bristol Port Master Plan 2023).
• Not Justified –  Evidence base flawed. No noise modelling (M5) or archaeological evaluation; high flood risk in Zones 2/3 per Defra MAGIC maps, with Environment Agency holding objection pending sequential tests (NPPF para 174); not “grey belt” (para 148). The Sustainability Appraisal contains no assessment of the loss of best and most versatile agricultural land. The entire site is classified as Grade 1 (excellent quality) according to Defra’s Provisional Agricultural Land Classification (see attached screenshot from magic.defra.gov.uk). This is prime farmland that the NPPF (para 119 and Planning Practice Guidance) says should only be developed as a last resort after all reasonable lower-grade alternatives have been exhausted. No such alternatives assessment has been carried out, rendering the allocation not justified (NPPF para 36(b)).
• Not Effective – The council’s own Infrastructure Delivery Plan (Oct 2025, §8.3) labels M5 Junction 19 upgrades as high-risk and unfunded. This site alone would generate approximately 280 peak-hour vehicle trips (1.4 cars per home × 200 dwellings) that must exit directly onto the Junction 19 / Marsh Lane / dock access network. When added to the remaining Portishead allocations and the ongoing expansion of Royal Portbury Dock HGV traffic, the cumulative impact has no evidenced or funded mitigation. National Highways has raised unresolved objections to the capacity and safety of Junction 19. In the absence of any robust assessment or deliverable mitigation, the allocation fails the effectiveness test (NPPF para 36(c)) and would cause severe residual cumulative impacts on the strategic road network (NPPF para 116). PRoW upgrade to services unfeasible without dock operator consent; active travel links (River Avon Trail, Marsh Lane) cross sensitive habitat without mitigation.
• Inconsistent/Legally Non-Compliant – Breaches NPPF para 148 (Green Belt without alternatives), para 193c (habitat harm), and Policy LP14 (no harm to dock operations). Duty to Cooperate failed: No joint Statements of Common Ground with Environment Agency (flooding) or National Highways (J19); ignores prior consultee holding objections from March 2025.

This allocation risks Plan-wide unsoundness, exacerbating gridlock and flood risks.

 

Modifications required

Delete Land East of Gordano Services from Schedule 1 and the proposals map. Revert to non-strategic status under July 2024, allowing small-scale (e.g., 10–20 homes) if traffic resolved. If retained, require pre-allocation: Resolve EA/National Highways objections via funded flood/J19 mitigations, full noise/heritage assessments, and dock compatibility study.

 

Wish to appear at hearing? Yes – We represent 4,200 residents with unique evidence (local flood records, M5 noise data, dock traffic logs). Hearings essential to cross-examine NSC/Environment Agency/National Highways on unresolved objections and push deletion, ensuring Inspector prioritizes parish impacts over developer gains.

 

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

Pill Green (HE2015) 

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

The Parish Council objects to Pill Green (HE2015) for 600 dwellings under LP4. Universal drop-in opposition—no one spoke in favour; all cited unsustainable traffic (~30% parish increase), no viable road access, “fictional” active travel routes, and irreparable Markham Brook damage (contradicting EIP 2025’s ancient woodland protections and NFM via buffers).

This is the largest and most damaging of the five LP4 sites, lying entirely in the Green Belt and containing floodplain woodland, ancient woodland and priority habitat.

• Not Positively Prepared – 600 homes would increase the parish housing stock by around 30% in one go, completely overriding our Neighbourhood Plan (81 % referendum support 2021) which caps growth at 150–200 homes to 2038.
• Not Justified – The Sustainability Appraisal ignores Defra MAGIC maps showing over 55 % of the site is floodplain woodland in Flood Zones 2/3 and ancient woodland at Markham Bottom. The proposed active travel overbridge and continuation of Bridleway LA8/33/40 would destroy irreplaceable habitat with no 15 m buffer and no compensation strategy (NPPF para 193c; Natural England Standing Advice 2024). No evidence proves this is “grey belt” or that exceptional circumstances exist (NPPF para 148). The Sustainability Appraisal contains no assessment of the loss of best and most versatile agricultural land. The vast majority of the site is classified as Grade 2 (very good quality) with significant pockets of Grade 1 (excellent quality) according to Defra’s Provisional Agricultural Land Classification (see attached screenshot from magic.defra.gov.uk). This is prime farmland that the NPPF (para 119 and Planning Practice Guidance) says should only be developed as a last resort after all reasonable lower-grade alternatives have been exhausted. No such alternatives assessment has been carried out, rendering the allocation not justified (NPPF para 36(b)).
• Not Effective – The council’s own Infrastructure Delivery Plan (Oct 2025, §8.3) labels M5 Junction 19 upgrades and Pill flood-risk management as high-risk and unfunded. Adding ~840 peak-hour car trips (1.4 cars/home) from this site alone – on top of Portishead growth and expanding dock HGV traffic – has no evidenced mitigation and no funded solution**. National Highways has raised unresolved objections to the cumulative impact on Junction 19 capacity and safety. In the absence of any robust assessment or deliverable mitigation, the allocation fails the effectiveness test (NPPF para 36(c)) and would cause severe residual impacts on the strategic road network (NPPF para 116). The site-specific requirements admit no increased surface water run-off is permitted and flood mitigation is needed downstream, yet no viable scheme is shown. The primary school and Markham Brook overbridge are unfunded and cross third-party land with no delivery mechanism.
• Inconsistent with National Policy & Legally Non-Compliant – Direct loss of irreplaceable habitat (para 193c), failure of sequential flood test (para 174), breach of Green Belt policy (para 148), and Localism Act 2011 (developer-led, ignoring 2,000-signature petition). Duty to Cooperate failed: no joint work with Environment Agency or Natural England on flood/habitat solutions.
• The Feb consultation listed HE2015 as a standalone village site (600 homes indicative), not strategic—yet June Cabinet aggregated it into LP4 without re-consulting on cumulative harms, misrepresenting objections as ‘localised’ support (para 3.21)

This site alone risks the entire Local Plan being found unsound.

 

Modifications required

Delete Pill Green (HE2015) in its entirety from Schedule 1 and the proposals map. Revert to the July 2024 spatial strategy under which this land remained protected Green Belt with no strategic allocation.

 

Wish to appear at hearing? Yes – We represent 4,200 residents with unique evidence (MAGIC maps, flooding photos, ancient woodland records, daily traffic experience). Hearings are essential to cross-examine the council, Environment Agency and Natural England on the complete absence of viable flood and habitat mitigation, and to press for deletion of this destructive site.

 

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

Land at Pill Road (HE20492)

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

Reasons

The Parish Council objects to Land at Pill Road (HE20492) for 100 dwellings under LP4. Every resident we’ve spoken with strongly opposed this site, no support voiced, only fact-based concerns on flood risks, habitat loss and undeliverable connections.

This Green Belt site south of Markham Brook is undeliverable due to severe flood risk, habitat destruction and lack of infrastructure.

• Not Positively Prepared – Further erodes our Neighbourhood Plan (81 % referendum support 2021) which caps total growth at 150–200 homes to 2038.
• Not Justified – The Sustainability Appraisal and site requirements ignore Defra MAGIC evidence that the site lies in Flood Zones 2/3 and directly abuts Markham Brook floodplain woodland and ancient woodland. The required active travel connection and overbridge would destroy irreplaceable habitat with no 15 m buffer and no compensation strategy (NPPF para 193c; Natural England Standing Advice 2024). No proof this is “grey belt” or that exceptional circumstances exist (NPPF para 148). The Sustainability Appraisal contains no assessment of the loss of best and most versatile agricultural land. The entire site is classified as Grade 2 (very good quality) according to Defra’s Provisional Agricultural Land Classification (see attached screenshot from magic.defra.gov.uk). This is prime farmland that the NPPF (para 119 and Planning Practice Guidance) says should only be developed as a last resort after all reasonable lower-grade alternatives have been exhausted. No such alternatives assessment has been carried out, rendering the allocation not justified (NPPF para 36(b)).
• Not Effective – Undeliverable. The site-specific wording admits “no increased surface water run-off will be permitted” and “flood risk mitigations will be needed downstream”, yet no viable scheme is evidenced. The Markham Brook overbridge is unfunded, crosses third-party land, and relies on the equally undeliverable Pill Green allocation (600 homes). IDP Oct 2025 (§8.3) confirms flood-risk management and J19 upgrades are high-risk and unfunded.
• Inconsistent with National Policy & Legally Non-Compliant – Direct loss of irreplaceable habitat (para 193c), failure of sequential flood test (para 172-175), and breach of Green Belt policy (para 148). Duty to Cooperate failed: no joint work with Environment Agency on flood mitigation or Natural England on habitat protection.

Modifications required

Delete Land at Pill Road (HE20492) from Schedule 1 and the proposals map. Revert to the July 2024 spatial strategy under which this land remained protected Green Belt with no strategic allocation.

 

Wish to appear at hearing? Yes – We represent residents with direct evidence of regular flooding on Pill Road and Markham Brook, plus MAGIC maps showing ancient woodland. Hearings are essential to question the council and Environment Agency on how they can claim “no increased run-off” is achievable when the site is floodplain, and to press for deletion.

 

Attachments

Defra MAGIC map extracts (flood zones & ancient woodland)

ALC Defra MAGIC Pill Sites Grades 1 and 2 Dec2025

 

Land at Ham Green (HE20493) – Parish Council Representation

Sound? No (Unsound on all four tests) Legally compliant? No Duty to Cooperate? No

 

Reasons

The Parish Council objects to Land at Ham Green (HE20493) for 40 dwellings under LP4. Drop-in feedback was positive on location for parish needs (especially affordable homes), but unanimous concern over traffic buildup on narrow Perrett Way—residents fear it becoming a rat-run. Still undeliverable overall.

 

• Not Positively Prepared – Adds to LP4 overload, overriding Neighbourhood Plan cap despite local support for sensible siting.
• Not Justified – No evidence that this Green Belt site is “grey belt” or that exceptional circumstances exist (NPPF para 148). The requirement to compulsorily upgrade and extend the private Perrett Way as public highway has no landowner agreement, no costed scheme, and no viability assessment.
• Not Effective – Undeliverable. Perrett Way is a narrow private road serving existing homes; turning it into a through-route for 40+ new houses will create traffic, safety and privacy issues for current residents. No funding or delivery mechanism is identified for the upgrade or the ‘proportionate contribution’ to wider active travel routes. Cumulative impact with the other four LP4 sites remains unmodelled (NPPF para 116).
• Inconsistent with National Policy & Legally Non-Compliant – Breaches Green Belt policy (para 148) and risks infringing private property rights without due process.

Modifications required

Delete Land at Ham Green (HE20493) from Schedule 1 and the proposals map, if retained post-LP4 withdrawal, cap at 20–30 affordable homes with Perrett Way safeguards (no through-traffic)

Wish to appear at hearing? Yes – Residents of Perrett Way and Ham Green will be directly affected by the forced public upgrade of their private road. We can provide on-the-ground evidence of ownership, current use and safety concerns that the council has completely ignored.

 

 

This a reminder that a drop in session will be held between 7pm and 9pm on Tuesday, 9 December at Pill Memorial Club where Parish Councillors will be available to hear your views about the NSC Local Plan consultation about future housing developments in the area, including this parish.  Please feel free to stay for as long as you wish.

Free tea, coffee, and biscuits will be provided.

The consultation closes at 5:00 pm on Friday, 12 December—this may be your last meaningful opportunity for years to influence the outcome.

Please see this previous bulletin on our website for further details.

https://peig-pc.gov.uk/news/urgent-your-views-needed-on-the-future-of-pill-easton-in-gordano

 

 

The A369 Junction 19 Interchange will be closed overnight from from 20:00 to 06:00 for up to 21 days beginning 3rd December because of emergency works undertaken by National Highways for urgent Bridge Joint Repairs.  This section of road will be closed to all vehicles, except emergency and works vehicles.

However, the closures may not be implemented for the whole of the period but only as necessitated by the works which is anticipated to be of 2 nights in duration. 

ALTERNATIVE ROUTE 

Motorway traffic diverted via J20 abd return to J19

Non motorway traffic diverted via High Street, Mill Lane, Clevedon Road – Beggar Bush Lane – Abbots Leigh Road

A369 Junction 19 Interchange, Martcombe Road, High Street, Mill Lane, Portbury Lane, Clevedon Road, Charlton Drive, West Hill, Tickenham Hill, Tickenham Road, Old Tickenham Road, All Saints Lane, Walton Road, Bristol Road, Portbury Common, The Portbury Hundreds 

For more details please see the attached road closure notice.

Our brand-new community defibrillator is now installed and fully operational!

You’ll find it proudly mounted on the front wall of The Duke of Cornwall pub – in a highly visible spot where it can be reached quickly in an emergency. After some challenges with the original location, this prominent position is actually even better.

A huge THANK YOU to:

• A wonderfully generous anonymous donor who very kindly funded the entire defibrillator – your kindness will help save lives in our village.
•  Josh Headford (electrician) for the expert installation.
•  John Murphy and everyone at No Hope Bars (owners of The Duke of Cornwall) and especially Emma Holden and the team for being so accommodating and supportive.
•  Cllrs Kat Raines, Bob Buck and everyone who helped get it registered on The Circuit (the national defibrillator network).

This is the latest life-saving outdoor defibrillator in our parish – you can see the full list of locations and a map on our defibrillators page.

In an emergency every second counts – please take a moment to familiarise yourself with where they all are.

We’ll now be setting up a simple monthly checking rota. If you’d like to help keep an eye on any of our parish defibs, please get in touch!

Thank you again to everyone who made this possible. Together we’re making our community even safer.