Site Allocations Plan March 2016

Comment ID 14402625//2
Document Section Site Allocations Plan March 2016 Schedule 1: Proposed large sites for residential development over 10 dwellings (Sites marked with a * are mixed use sites). Service Villages Says Lane, Churchill View all on this section
Respondent Deleted User View all by this respondent
Agent CH
Response Date 28 Apr 2016

These representations are made regarding the draft Site Allocations Plan and are submitted by Turley on behalf of Edward Ware Homes Ltd and Mr J Burdge who have interests at two sites in Langford. Attached is a site location plan showing the extent of the land that our clients control.

The sites both adjoin the settlement boundary of Langford and are to the south of the A38 (Bath Road) along which lies existing development including dwellings a guest house, a hotel and a pub.

The sites are subject to few environmental constraints, both are within a Bat Habitat area, although this designation also covers the entirety of the adjoining settlement. The sites are relatively flat and are not subject to any local or national designations which would inhibit residential development on the site. In addition, there are no other known significant constraints, including flooding, which would affect the potential delivery of residential development on these sites

The two sites benefit from strong existing vegetation along their boundaries and are well contained within the wider landscape of Langford. In addition, both sites sit well within the existing linear form of residential development along Bristol Road. Effectively the development of the two sites would complete the existing linear development along the Bristol Road and would form complete enclosure along that section of Bristol Road.

The northern most of the two sites is currently subject to an outline application by our clients (application ref. 15/P/1313/O) which was considered at committee 9 March 2016 and has a resolution to grant planning permission for 43 dwellings. That site is also now one of the draft housing allocations in the Part 2 Plan.

Sites and Policies Plan Part 2; Site Allocations Plan

The Sites and Policies Plan Part 2; Site Allocations Plan to which these representations relate proposes to include one of our client’s sites as a proposed residential allocation. This allocation is fully supported by our client. That site is entirely appropriate for residential development and the site now has a resolution to grant planning permission for 43 homes under application ref. 15/P/1313/O. We expect the Section 106 on this application to be completed shortly.

However, the southern site is not proposed to be allocated for residential development and we would suggest that this site is also entirely appropriate for residential development given that it has a similar relationship to Langford, is equally well contained in the landscape and has similar limited environmental constraints. This site is therefore also suitable for residential development and should be allocated as such in order to ensure the District meets its future housing needs.

In the light of the above, we would therefore request the following policy revisions;

Policy SA1 of the draft Allocations Plan sets out the purpose of the settlement boundaries as shown on the Proposals Map. Given that the Proposals Map shows the northern Bristol Road site as a proposed allocation it would be consistent with the proposed policy to include it within the settlement boundary. Furthermore given the suitability of the southern site for development it too should be included within the settlement boundary for Churchill/Langford.

Policy SA2 refers to the allocation of residential sites of 10 or more units; it refers to Schedule 1 which identifies the northern site as ‘Says Lane, Churchill’ a site with a capacity of 43 units. The second site, the southern most area, is also suitable for development with a similar capacity of up to 50 dwellings, it would be appropriate therefore to also include this site in Schedule 1 and allocate for residential development.

Status of the Site Allocations Plan

The purpose of the Site Allocations Plan is to identify detailed allocations required to deliver the Core Strategy. However, several policies, importantly including policies relating to the distribution of new housing, remain remitted following the legal challenge to the plan in 2013. Although the Council now have a revised adopted housing requirement (20,985 dwellings between 2006 and 2026) remitted policies to govern how this requirement will be distributed have not yet been re-examined.

The Council describe the Site Allocations Plan as ‘a transitionary plan’ given that the Core Strategy will be reviewed by the end of 2018. However, the conclusion of the re-examination of the remitted policies is unknown and hearing sessions on this are not programmed until June 2016. We would question whether the Site Allocations Plan can be brought forward at this time given the extent of the uncertainty surrounding the re-examination of key elements of the Core Strategy.

Furthermore the West of England Local Authorities are currently collaborating to prepare the Joint Spatial Plan, the distribution of the additional housing allocations between the authority areas has not been established. This joint plan must ensure the region’s growth is accommodated in sustainable locations: - given that the ‘share’ of growth to be accommodated within North Somerset has not been determined there is a real danger that sites brought forward through this Site Allocations Plan ahead of these decisions will simply not be sufficient. This provides greater justification for the positive allocation of appropriate sites that seek to take a longer term and proactive approach to meeting both current and future housing needs.

Housing Requirement and Housing Supply

The revised adopted housing requirement for the district is a minimum of 20,985 over the plan period as confirmed by the Secretary of State in September 2015. As set out in the draft Allocations Plan 7,426 dwellings have already been completed over the plan period from April 2006 to April 2015. This leaves a residual requirement of 13,559 to be identified to 2026. Furthermore this figure is expressly stated to be a minimum requirement, it would be prudent for the Council to treat this figure as a minimum and ensure that potential delays and non-implementation of sites does not result in a lack of five year supply or indeed, under delivery across the plan period. Consequently, in line with the NPPF’s requirement to boost significantly the supply of housing and to maintain delivery of five-year supply the Council should be allocating a greater amount than the minimum required in the Site Allocations Plan.

At Table 1 of the draft Allocations Plan the Council states that it has a total commitment figure of 21,114 dwellings over the plan period. However this is just 219 above the minimum requirement and, as set out below the claimed sources of this supply are not fully and robustly evidenced.

Table 1 of the draft Allocations Plan identifies a total potential supply (including completions to date) of 21,114 dwellings. 1,200 of these are from windfalls; the table states that the figures are based on past rates and on page 14 the draft Plan gives the following explanation ‘windfall sites are sites which have not been specifically identified as available but based on past building rates will come forward over the remainder of the plan period’. This is the only apparent evidence given for the inclusion of this level of windfall and it is not sufficient justification for this figure. In line with the NPPF (paragraph 48) authorities should only include windfall sites in the five year supply if they have compelling evidence that such sites will become available. No such compelling evidence has been provided and this level of windfalls should not be relied upon.

Table 1 also includes 225 units contributed to the supply from ‘other large sites with consent (not proposed to be allocated)’. The explanation of what this category of supply comprises states that these are sites that are expected to be built out before public consultation of the document and those with a permitted development change of use consent that would otherwise be contrary to policy. These sites are not however clearly distinguished at Schedule 1 and it is not clear whether an appropriate non-implementation discount has been applied to them. Without such clarity we would question the justification for relying on this level of supply from this source.

Schedule 1 also details several sites, without a current consent, carried over from the North Somerset Replacement Local Plan. These sites make a substantial contribution to the Council’s claimed supply; for instance Westacres Caravan Park is stated as having capacity of 100 units, and Land north of the A370 with a capacity of 80 units, however these sites do not currently have planning consent and it is not therefore certain that these sites will come forward. Furthermore, these sites have been carried over from the previous Local Plan which was adopted nearly 10 years ago, in 2007, given that these sites have been allocated for a significant amount of time with no development coming forward, the Council should not be continuing to rely on their contribution to its overall housing needs.

The Council also, at Schedule 1, include contributions from C2 unit schemes including, for example, 124 units from a proposed care village at Redwood Lodge. However, the PPG (reference ID 3-037-20150320) states that:

“Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.” (emphasis added)

In North Somerset, the approach to be taken to older people is not clearly set out in the Core Strategy as required by PPG. It is not clear whether the overall housing requirement in the Core Strategy of 20,985, includes provision for the specific needs (and number of C2 units/beds) required for older persons. Unless the Council is able to specifically identify that the full needs for older persons are accommodated within the overall housing requirement and until such time as the approach taken is clearly set out in a local plan (which it is not in either the Core Strategy or in the draft Part 2 Plan) then sites which will provide C2 units should not be included as counting towards the Council’s overall housing requirement.

Given that the Council have made generous assumptions on what level of the identified sites will actually contribute to the supply, that windfalls have been relied upon, that no apparent non-implementation discount has been applied, that old Local Plan sites are carried forward despite concerns about delivery, that C2 uses are shown as contributing to supply, and that the housing figure is a minimum only; we would suggest that the Council should plan to delivery more than a mere 219 additional units above the minimum figure over the plan period. Sites such as our client’s land at Langford that are sustainable, developable and sustainable should be allocated for development, given that the Council has done this for one of the site’s, and both areas were assessed together as being developable in the site assessments there is no reason for the southern Langford site to not also be allocated.

Suitability of the Sites for Development

The adopted North Somerset Core Strategy identifies Churchill (which includes Langford) as a Service Village, which benefits from a range of existing services and facilities. Although the policies relating to the distribution of development within the District have been remitted, Churchill/Langford remains a sustainable local to accommodate growth.

Appendix 1 to the Sustainability Appraisal which comprises part of the consultation documents accompanying the draft Allocations Plan contains the individual assessment of residential sites put forward for development by developers. Our client’s sites were considered as part of a wider area detailed as ‘Land at Says Lane’ (site ref. NS0029) for which the conclusion was that the site should be allocated for housing in the Site Allocations Plan as it is ‘close to facilities and no significant adverse impact on landscape’. The current draft Plan does not follow the Council’s own recommendations and only allocates the northern Langford site for development. In accordance with its own assessment, our client’s second site, as assessed as equally sustainable should also be allocated for residential development given that this is a deliverable site suitable to contribute to meeting the future housing needs of the District.  

In the assessment site ref. NS0029 scored green on 4 categories, amber on 9 and red on only 3. The red categories were ‘nearest town’, ‘PDL/Greenfield’ and ‘policy’. Criteria 4.4 relates to previously developed land and we accept that as the site is green field it complies with the red scoring for this category. Criteria 5.2 however relates to settlement boundaries and clearly states that sites ‘adjacent to the settlement boundary’ should be classified as amber not red. We would therefore request that this assessment be amended to properly reflect the accurate location of these sites; adjoining the settlement boundary.

Furthermore, as detailed on the Assessment Guide to these tables category ‘2.4 nearest town’ (or 2.5 as it is incorrectly stated within the Chruchill tab of the spreadsheet) refers to whether the proposed site can reasonably access town centre services and facilities. It clearly states in the criteria that the site should score green if it is ‘within or on the edge of a town or service village’. Given that the site adjoins a service village and is in close proximity to local services and facilities including schools, pubs, a shop and a petrol station it is unreasonable and inaccurate to classify this site as red which is defined as ‘countryside/greenbelt – further than 10km from the nearest town’.

With these corrections made based on the Council’s own criteria these sites would score just 1 red, 11 ambers and 4 greens.


The potential capacity of the sites to deliver 43 and approximately 50 dwellings respectively is development of an appropriate scale for this settlement which would make efficient use of each site and fit well into the surroundings. The development of these sites would result in benefits to the local community in the form of high quality new homes, including affordable housing, support for local services and the creation of public open space

The identification of sites which are suitable, available and deliverable is important to ensure that housing needs are met, as well as supporting community infrastructure. Both of the submission sites are suitable, available and deliverable.