Site Allocations Plan March 2016

Comment ID 8141345//1
Document Section Site Allocations Plan March 2016 Evidence Base Evidence Base View all on this section
Respondent Deleted User View all by this respondent
Response Date 27 Apr 2016

Highways England welcomes the opportunity to comment on the Consultation Draft of the Site Allocations Plan (the Plan) which will form Part 2 of the Sites and Policies Plan. Highways England is responsible for operating, maintaining and improving the Strategic Road Network (SRN), which in North Somerset comprises the M5, starting from between junctions 18 and 19 and down to the south of junction 21. It is on the basis of these responsibilities that the comments that follow in this letter have been made.

We are keen to ensure that policy takes account of the need for transport and land use planning to be closely integrated. In this respect, consideration should be given to the provisions of DfT Circular 02/2013 - The Strategic Road Network and the Delivery of Sustainable Development, which sets out how Highways England will engage with the planning system to deliver sustainable development.

We recognise that the efficient operation of infrastructure is essential to supporting sustainable economic growth and we therefore aim to support growth and facilitate development, based on an understanding of traffic conditions and behaviour, to manage the effects of development and ensure road safety. In order to constructively engage in the local plan-making process we require a robust evidence-base so that sound advice can be given to local planning authorities in relation to the appropriateness of proposed development in relation to the SRN and any measures which may be required to support the delivery or mitigate the impact of potential site allocations.

Paragraph 12 of Circular 02/2013 states that, ‘The preparation and delivery of Local Plans provides an opportunity to identify and support a pattern of development that minimises trip generation at source and encourages the use of sustainable modes of transport, minimises journey lengths for employment, shopping, leisure, education and other activities, and promotes accessibility for all. This can contribute to environmental objectives and also reduce the cost to the economy arising from the environmental, business and social impacts associated with traffic generation and congestion.’

Paragraph 18 states that, ‘Capacity enhancements and infrastructure required to deliver strategic growth should be identified at the Local Plan stage, which provides the best opportunity to consider development aspirations alongside the associated strategic infrastructure needs. Enhancements should not normally be considered as fresh proposals at the planning application stage. Highways England will work with strategic delivery bodies to identify infrastructure and access needs at the earliest possible opportunity in order to assess suitability, viability and deliverability of such proposals, including the identification of potential funding arrangements.’

Highways England’s response to Local Plan consultations is also guided by other pertinent policy and guidance, namely the National Planning Policy Framework and Highways England’s Local Plan Process protocol.


We have been involved throughout North Somerset’s development plan preparation process and have generally been content with the levels of development identified and with the employment led development emphasis that forms a long standing spatial objective, seeking more sustainable development patterns by improving self-containment and reducing out commuting. We have previously carried out modelling to determine the potential implications of the largest sites allocated in the Core Strategy forming part of the Weston Villages development, with a particular focus on the M5 Junction 21. It has previously been noted that whilst major highway schemes proposed will help facilitate the level of growth proposed, the phasing of developments and these infrastructure improvements is vital to ensure that capacity comes before growth.

We previously responded to the consultation on the Development Management Policies Publication Version, which forms Part 1 of the Sites and Policies Plan in March 2015, however most recently we responded to the consultation on consequential changes to remitted Core Strategy policies CS6, CS14, CS19, CS28, CS30, CS31, CS32, CS33 in December 2015, following the legal challenge on Policy CS13 and subsequent revision and adoption of the policy, which increased the overall housing requirement from 14,000 to 20,985 dwellings.

Site Allocations Plan Consultation Draft

Highways England is keen to ensure that the Plan takes account of the need for transport and land use planning to be closely integrated, and that the principles of sustainable travel are reflected when assessing the suitability of sites. As noted above, Circular 02/2013 emphasises that the best opportunity to prepare and assess the evidence required to appropriately consider the Plan’s development aspirations, alongside associated strategic infrastructure needs, should be during the preparation of the Plan and not when new proposals are submitted at the planning application stage. We are therefore keen to ensure that the sites promoted through this Plan are supported upfront by the necessary evidence to demonstrate that they are viable and can ultimately be sustainably delivered, either with or without mitigation, and without detrimentally impacting on the safety or operation of the SRN.

It is noted that none of the evidence base documents referred to in Section 3 of the Plan relate to highways or transport infrastructure and no further evidence base documents have been published to support this consultation. Therefore, we have only been able to provide general comments on the policies and sites in the Plan and our comments below are provided on the understanding that the only currently available evidence in relation to transport infrastructure is that submitted in support of the Core Strategy, namely the: Joint Local Transport Plan 3; Joint Local Transport Plan Progress Report; Draft Infrastructure Delivery Plan; and Development Contributions SPD, and Highways England’s own modelling of the Core Strategy’s strategic sites on Junction 21 of the M5.


There is no new transport evidence base presented in (or accompanying) the Plan, and therefore only general comments have been able to be provided at this time. We understand that the only evidence available is that provided in support of the Core Strategy. The overall housing provision has increased by approximately 7000 dwellings from that proposed initially in the Core Strategy and upon which the existing evidence was based. Consequently it may be necessary to reaffirm that the measures proposed in the Core Strategy remain appropriate and will be capable of supporting this increased level of growth.