Proposed level of development in Nailsea of 885 new houses cannot be considered to be sustainable in the current climate.

Show sequential risk based approach. Some sites impacted by flood zones 2 / 3. Show proposal can pass Sequential / Exception Tests, considering need as part of equation. Sites in 2 / 3 need Flood Risk Assessment, showing development will be safe for its lifetime, inclusive of climate change, without increasing flood risk elsewhere and where possible reducing flood risk overall. Consult LLFA on surface water drainage, also IDB. Development should accord with NPPF and Development Plan.

It is clear on the current evidence base, that the Council are unable to provide appropriate justification for their site selections, nor evidence to illustrate that their approach is consistent to that put forward in national planning policy.

Impact on bats not fully recognised in HELAA for West of Engine Lane site

Disappointed that the HRA hasn't been made available

No new transport evidence is presented so only general comments have been able to be provided. We understand the only evidence available is that for the Core Strategy, for which the housing provision has increased by about 7000 dwellings from the level on which the existing evidence was based. It may be necessary to reaffirm that the Core Strategy's measures remain appropriate and able to support this higher growth

No new transport evidence base is in the Plan, so only general comments have been possible.The only evidence available is for the Core Strategy. No further assessment has been done re mitigation for policies/allocations in this Plan, or to show they are viable, fundable, deliverable. The overall housing provision has increased by about 7000 dwellings from that on which existing evidence was based, so it may be necessary to reaffirm that measures in the Core Strategy remain appropriate.

Need to clarify, in greater detail, the heritage evidence that has applied to inform the conclusions derived by the SA Residential Site Assessment which provides very little background explanation and no reference to the evidence which has been applied (such as the Historic Environment Record) and by who. It is important to demonstrate that special regard and great weight is given to the conservation of the significance of affected designated heritage assets

Habitats Regulations Assessment (HRA) We note that the Council intends to finalise the Habitats Regulations Assessment (HRA) at the Publication stage and trust that the proposed allocation at Birnbeck will be carefully considered as part of this assessment.

It is crucial that the Council have an up-to-date and robust evidence base in order to plan for the provision of sport both playing fields and built facilities. Sport England would highly recommend that the Council undertake a playing pitch strategy (PPS) as well as assessing the needs and opportunities for sporting provision. Sport England provides comprehensive guidance on how to undertake both pieces of work.