North Somerset Local Plan 2038 Preferred Options

Comment ID 9143457//4
Document Section North Somerset Local Plan Preferred Options: Consultation Draft March 2022 3. Strategic Policies SP3: Spatial strategy SP3: Spatial Strategy View all on this section
Respondent Nick Matthews View all by this respondent
Response Date 29 Apr 2022
Please select one of the following statements:
  • Support the policy allocation with amendments (provide details in the comments box below)

Policy SP3: Spatial Strategy
3.9 This draft policy sets out the overall approach for the location of development within North Somerset over
the plan period. We provide comments in relation to individual aspects of the policy wording in turn below.
1. ‘The Local Plan makes provision for a minimum of 20,085 new dwellings and 70 ha employment land
within North Somerset over the plan period 2023-2038.’
3.10 As previously outlined within Representations made in response to the Pre-Commencement Document in
March 2020, we have concerns over the soundness of both the start and end dates of the proposed plan
period and the effect of these on the overall housing requirement. We do not reiterate these again here but
direct officers back to our previous submission in March 2020.
2. ‘Priority will be given to locating new residential and mixed-use development in or close to urban areas
where there is an existing or proposed wide range of facilities, services and jobs, and there are
opportunities to encourage active travel, particularly at locations which are currently, or have the
potential to be, well served by public transport.’
3.11 We strongly support the approach adopted within this wording, which encourages residential and mixed-use
development in or close to urban areas that can and/or do provide a range of facilities, active travel
opportunities and public transport. Transport accounts for approximately one third of carbon emissions
across the UK as a whole. It is entirely consistent with national policy and the Council’s declaration of a
climate emergency to prioritise development in locations which are or can be made accessible to a wide
range of services and facilities. There are also further social and economic benefits to minimising travel, and
in particular work-based commuting.
3.12 Policy SP3 is very broad in its approach. What it does not explicitly acknowledge is that within North
Somerset there is a hierarchy of settlements with some offering a far wider range of services and facilities
than others. Those settlements with a greater level of provision are typically better placed to accommodate
a greater scale of development in a more ‘sustainable’ manner.

3.13 When considering the hierarchy it is important not to confine the analysis only to those settlements within the
authority area. The urban edge of Bristol abuts part of the administrative boundary with North Somerset and
development which has potential to connect sustainably into the services and facilities of Bristol is capable
of accommodating a greater scale of development and should be higher up the hierarchy than the towns and
villages within North Somerset.
3.14 It not just the sustainability of the settlements themselves though which should inform the spatial strategy but
a broader understanding of the dynamics of the housing and employment markets. Bristol has a major
bearing on both the housing and employment markets of North Somerset. In relation to employment, as the
Stage 3 Transport Assessment concludes:
“Commuting patterns of the four main towns have been analysed. Clevedon, Nailsea and
Portishead show a high level of out-commuting to Bristol. Weston-super-Mare shows significantly
higher levels of self-containment, albeit Bristol still exerts a reasonable draw”.
3.15 The ability to connect into the employment opportunities within Bristol via sustainable modes of travel will
therefore have a significant bearing upon levels of travel, car use and ultimately the achievement of the
authority’s climate emergency and sustainability objectives.
3.16 The housing market of North Somerset has similarly close ties with Bristol. Evidence published by ONS1
demonstrates that over the past five years there has been the following flow of people between the
Year Bristol > North Somerset North Somerset > Bristol
Net Flow into North
Somerset from Bristol
2020/21 2,431 1,053 1,378
2019/20 3,040 1,326 1,714
2018/19 2,935 1,289 1,646
2017/18 3,160 1,270 1,890
2016/17 2,810 1,210 1,600
Total 14,376 6,148 8,228

Indeed, over the five years, on average there has been 1,646 people moving to North Somerset from Bristol
each year. The evidence provides no explanation why there is this flow, however, based on experience of
the wider housing market, it is likely to be a result of the constrained supply in the Bristol market not matching
demand and the inevitable flow of households to locations further afield to meet their housing needs. The
shortage of family housing is particularly acute due to the high proportion of apartments in Bristol. This has
resulted in many families moving to the towns and villages of North Somerset to find suitable accommodation.
3.18 Many of the households moving to North Somerset will retain strong functional links with Bristol whether that
is for employment, education or otherwise, with the net result being high levels of commuting back from North
Somerset to Bristol. It is not possible for the planning system alone to control or change this pattern but it is
important that the spatial strategy of the Local Plan is cognisant of these wider market dynamics and has
regard to their implications in planning for the most sustainable form of development.
3.19 What does this mean for the Local Plan? In our opinion this evidence indicates that growth closely related
to Bristol represents a very sound and justified component of the spatial strategy. In so doing it validates the
decision to allocate the new community at Yanley Lane and supports the proposed expansion of the
allocation as described in our response to Policy LP2.
3. ‘Employment opportunities will be encouraged at accessible locations well related to the urban areas
and where sustainable transport opportunities can be maximised.’
3.20 We strongly support the approach adopted within this wording, which encourages employment opportunities
to be provided in accessible locations where sustainable transport can be maximised. It is as, if not more
important for employment to be located where there is good access for future employees to sustainable travel
opportunities as it is for the residents of new homes. We will explain how the proposals by Taylor Wimpey
comply with this component of the Spatial Strategy later in this representation.
4. ‘Residential development in areas at risk of flooding will be minimised outside the towns.’
3.21 We support the approach adopted within this wording, which directs residential development away from areas
at highest risk of flooding.
3.22 The Council’s declaration of a climate emergency requires the authority to not only put in place plans for
development to be directed to the most sustainable locations but also to ensure the locations selected are
resilient to the effects of climate change. The avoidance of flood risk areas is arguably the most important
component of the latter. Climate change will result in unpredictable weather patterns and increase the risk
of flooding which can have disastrous effects on home owners and local communities. Given its importance,
we welcome the inclusion of this policy objective in the over-arching Spatial Strategy.

The only note of clarification that we would like to add is that decisions should be made on the basis of up to
date and accurate mapping of flood risk areas. There are instances where the Environment Agency (EA)
Flood Map for Planning are not entirely accurate. Where this is the case, the more up to date evidence
should be used as opposed to a strict adherence to published EA mapping.