Core Strategy-Examination into consequential changes of remaining remitted policies Proposed main modifications

Comment ID 14343521//2
Document Section Core Strategy-Examination into consequential changes of remaining remitted policies Proposed main modifications Policy CS28, Modification CC-MM04 [View all comments on this section]
Respondent Deleted User [View all comments by this respondent]
Response Date 05 Sep 2016

Revised Policy CS28 states that housing sites outside the settlement boundary "in excess of about 75 dwellings" must be brought forward as site allocations in the Local Plan or neighbourhood planning process. The requirement for new residential schemes in excess of "about 75 dwellings" is too prescriptive. It is considered that schemes should be judged on the merits of their sustainability in line with the provisions of the NPPF.

My client’s site at Lyefield Road is directly adjacent to the development boundary and is well located to the centres of Worle and Weston-super-Mare. Following highways advice, it is also considered that suitable access can be achieved from Lyefield Road. The site has no other designations, and remains available for development now.

It is critical to note here that from a sub-regional perspective, the site’s location adjacent to the settlement boundary of Weston-super-Mare is beneficial. Chapter 5 of the West of England Joint Spatial Plan (JSP) Issues and Options Document considers the development options that exist across the joint local planning authorities of Bristol City; South Gloucestershire; Bath and North East Somerset; and North Somerset. Table 5.1 of the document considers that an urban extension [urban extension being defined as a "planned expansion of the urban area into the adjacent countryside"] to Weston-super-Mare could be one of the most appropriate options. The proposed spatial strategy of extending existing towns adjacent to their settlement boundaries is one of the priorities of the JSP: therefore the development of my client’s site at Lyefield Road would be an acceptable option to meet the identified housing needs of the West of England sub-region.

One of the potential development options of the JSP was to protect the Green Belt. The West of England contains a considerable amount of land designated as Green Belt. My client’s site is not located within the Green Belt, and its development would contribute towards its preservation.

As set out in our representation in April 2016 (reference number M15/0213-02), the site is equal to or outperforms ten other sites which have been allocated within the Draft Site Allocations Plan. As also stated in our representation it is concerning that a large number of the sites which the Council propose to allocate are located within Flood Zones 2 and 3. The site is not located within Flood Zones 2 or 3 on the Environment Agency Flood Maps. It is also located in Flood Zone 1, which presents the lowest risk of flooding, and the category within which development is deemed to be acceptable.

As a result, the Council’s strategy risks allocating development in the most inappropriate locations, outside of Weston-super-Mare. The Plan also risks allocating development on those sites that are not as sequentially preferable than others – such as our site at Lyefield Road.