Site Allocations Plan March 2016

Comment ID 11219713//2
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 28 Apr 2016

Land to the North of the A368, Sandford, BS25 5QB

Pegasus Group submit this representation on behalf of Strongvox Homes in respect to their interest in land to the north of A368, Sandford.

We wish to raise a significant objection in respect to the robustness of the Council’s approach to site allocations; both an in-principle objection to the process, but also detailed concerns in relation to the evidence base underpinning the assessment.

General Approach

At the outset, a significant concern is raised in respect to the Council’s general approach to the site allocations process.

The Sustainability Appraisal (March 2016) underpinning the assessment sets out that the Council are seeking to plan for the ‘remainder’ of 1,715 units. This fails to reflect the findings of the Core Strategy Inspector who identified that the housing requirement was to be expressly stated as a minimum, given the particular concern that the Council had chosen the minimum figure in the OAN range. As detailed in the Inspector’s findings, the housing requirement was between 20,220 and 25,960 based on the Council’s own evidence base (#56, CS13 Inspector’s Interim Findings).

The NPPF requires Council’s to plan proactively to encourage sustainable development. Given the Council are aware that they are planning for the lowest point of OAN, it is not felt that the Council are consistent with the intentions of the NPPF.

At paragraph 3.9, the Council seemingly identify the requirement to consider a range of factors when considering site allocations, rather than applying a simplistic sequential test, however this does not appear borne out on evidence. Indeed, there are clear indications that the Council’s approach to directing such significant development to Weston Villages is saturating this market, and will result in reductions in trajectories as more developers come online. Despite this, the Council have seemingly sought to direct additional development to this location.

In addition, the Council’s approach (in #3.9) seemingly fails to appreciate the potential of residential development to meet wider sustainability aspirations; for example, acting as enabling development or performing a wider sustainability role.

The NPPF and PPG both explicitly reference the role of rural housing in performing a wider role in supporting the continued vitality and vibrancy of rural settlements. However, the Council strict application of a sequential search against the settlement hierarchy has essentially resulted in a blanket protection against allocation in Infill Villages. This is contrary to the PPG which explicitly states that blanket protection is not appropriate.

Beyond this, the allocation process has taken no account of the opportunities for development in a range of locations, beyond the Council’s basic sequential search, which could act as enabling development to meet localised affordable need, addressing ageing populations, support school expansion, provide additional community facilities or open space, improve existing traffic or transport problems etc. This failure raises significant concerns in respect to the simplistic approach, and concerns that the methodology and evidence underpinning it are not robust.

Sustainability Assessment

The Council have published a Sustainability Assessment as part of the evidence base for the Site Allocations DPD. However, this appears arbitrary and fulfils no obvious part of the evidence base.

The assessment states that it performs a role in allowing a settlement hierarchy to be established; however, as documented in the Core Strategy, the settlement hierarchy is based purely upon the Council’s own pre-defined list of the services that it expects to find within a Service Village as decided in 2007. Indeed, if the sustainability assessment was in fact seeking to review the settlement hierarchy, it would have resulted in a change given both Sandford and Locking scored the same sustainability score as the Service Villages of Banwell, Churchill and Wrington (Appendix D).

The robustness of this assessment is also questioned. Firstly, it fails to consider all Infill Villages – assessing only 4 of the 13; but also it contains a significant number of errors and makes a number of assertions with no evidential basis.

It is also noted that the underlying ‘sustainability’ strategy underpinning the report is based upon an approach which the Government have explicitly identified is contrary to current national planning policy; with the document which sourced these sustainability criteria since revoked (Written Statement, 16 January 2015).