Core Strategy - Consultation Draft

Document Section Core Strategy - Consultation Draft Chapter 5: SW Bristol Urban Extension Chapter 5: Introduction [View all comments on this section]
Comment ID 3620513/CSCD/17
Respondent LandTrust Developments Ltd [View all comments by this respondent]
Agent Deleted User
Response Date 19 Jun 2010
Current Status Accepted
Urban extension to the south west of Bristol
4.1 With the requirement for the housing provision for 2006-2026 to be made in this plan according to the Council's starting point and from the evidence to be at a level of at least 26,750, the plan is required to establish a spatial strategy that makes this provision.
4.2 The Council's incomplete spatial strategy places great emphasis on
provision at Weston-super-Mare, through development sites and
conversions within the urban area and on land beyond the areas currently
developed for urban uses. In terms of the overall strategy for the West of
England, and to the area within North Somerset, Weston-super-Mare is
secondary to Bristol as a focus for new development. It has a vital role, and enhancing its local economy with employment-led regeneration is a vital objective, but this certainly does not point to housing development on the edge of Weston having priority over creating an extension to Bristol.
Fortunately the levels of development and community provision to be
achieved require for both forms of development to come about, and the
most appropriate strategy for North Somerset must therefore be one of
complementary development at Weston-super-Mare and Bristol.
4.3 The way that housing is envisaged to come forward in North Somerset
District, other than from urban extensions, is set out in pages 63-65 of the consultation document. A total of 11,152 dwellings is expected to come
- Completions since 2006
- Planning permissions as at April 2009
- Remaining allocations from the Replacement North Somerset Local
- Sites within the Weston Town Centre Area Action Plan Preferred
options document
- Windfall assumptions for the last seven years of the plan period.
4.4 There are a number of factors that suggest the figures are higher than they should be and hence there is a significant likelihood that the actual delivery will be lower. These factors include:
- The expectation that in making a Local Development Framework,
unimplemented allocations from an existing Local Plan will be
reviewed against the current national and regional policy position
rather than simply carried forward
- Sites within the Weston Town Centre Area Action Plan Preferred
Options document are not yet allocations and so it cannot be assumed
that they will all be implemented
- The general expectation that not all sites with permission will be
implemented, something frequently reflected by the application of a
non-implementation allowance of 5 or 10%.
4.5 It is noted too that PPS3 says that allowances should not be made for
windfalls in the first 10 years of a plan period. Whilst this does not mean they will not come forward, and the consultation draft refers to the last 7 years of the plan period, the number of windfalls included is not identifiable form the consultation document and a Planning Inspector will certainly wish to ascertain whether the Council is relying on windfalls to an inappropriate degree.
4.6 The second main component of provision is the Council's wish and
expectation to see 5,750 dwellings delivered within the plan period at
Weston-super-Mare beyond the current extent of the town's built up area.
4.7 Most striking from the consideration of the figures is that the Council is planning for or at least accepting an 'over provision' (the term used in the consultation document) of 3005 dwellings at Weston-super-Mare in the plan period. This is clearly contrary to the Draft RSS, and threatens the general conformity of the Core Strategy. More fundamentally it is in direct conflict with the Council's own accepted belief that regeneration at Weston has to be led by employment, and that development at Weston-super-Mare has to be managed to redress the inbalance between homes and jobs. Whilst the Council may wish to see development taking place within Weston-super- Mare, with benefits for the physical fabric and providing support to the provision and maintenance of facilities and services, if this number of dwellings is to be provided within the town then the amount to come forward from the urban extension should be reduced correspondingly. That is, the urban extension to Weston-super-Mare provided for in the Core Strategy should only include 6,000 dwellings, with a corresponding reduction for the plan period to 2026.
4.8 The figures included in the consultation document show that there is a
requirement for 9,848 dwellings not provided for by a combination of
completed and committed development, the estimated potential for housing
to come forward in acceptable ways within existing settlements, and the
Council's intentions for the urban extension to Weston-super-Mare. This is
the 'gap' based on the Council's adopted Proposed Changes RSS figure for
the District. The figure is 9,098 if the Draft RSS figure is used.
4.9 Having regard to the form and future of the West of England as a whole, as well as to the settlement pattern in North Somerset, the greatest contribution to achievement of more sustainable development patterns in the future as well as the only realistic way to provide this scale of required development through this plan is by a well planned addition to Bristol. On the evidence of the figures from the consultation document and the credible sources of these figures, the development should provide at least 9,000 dwellings. This solution has been consistently promoted through every stage of the emergence of the RSS and acknowledged to be the way to meet this requirement by the West of England Partnership and by North Somerset Council itself. The First Detailed Proposals of August 2005 referred to above refer to an urban extension to the south of Bristol (para. 2.8), and
adjoining Bristol to the south west of Bristol for which detailed work on the green belt and on infrastructure provision will be required (para. 2.22). A meeting of the Executive of North Somerset Council on 11 July 2006 agreed
to support the provision of 7,500 dwellings in an urban extension to the
south west of Bristol, in the belief that this was the maximum that could be
delivered by 2026 (rather than representing the actual capacity of the area),
whilst recognisng a lack of more detailed evidence at that time.
4.10 There has been no demonstrably better alternative to this way of delivering
development beyond the edges of existing settlements throughout the whole
of the lead up to this consultation and the Council does not offer any
suggested alternative spatial patterns that would provide this development.
Indeed the consultation draft plan says at page 64 that: 'for the purposes of
housing numbers urban extensions will be treated as self-contained, and will
not be transferred elsewhere as this will result in dispersed, less sustainable
development contrary to RSS objectives'.
4.11 The creation of an urban extension to south west Bristol is an entirely
appropriate component of the overall spatial strategy, for many reasons:
- Extensions to major urban areas are the most sustainable way of
achieving development along with making use of underused land
within urban areas, and far preferable to freestanding development or
to additions to small settlements. It would in any case be impractical
to achieve the required amount of development in this way.
- This pattern most satisfactorily contributes to the objective of rebalancing
the corridor as described above, with homes added at the
Bristol end complementing the relative addition of jobs at the Westonsuper-
Mare end
- Urban extensions are a complementary form of development to the
development taking place within the urban areas, with the opportunity
to extend the city's greenspace, and provide more choice, a greater
housing mix and more family homes
- Large scale development provides the opportunity to plan the
provision of a mix of uses in from the outset, and provide for the best
relationship between homes with services and community facilities,
and to promote the most progressive forms of public transport, energy
provision and local management
- The urban extension in this case can be integrated and aligned with
the provision of transport infrastructure that is needed to the south and
south west of Bristol. North Somerset Council and the West of
England authorities are committed to the delivery of this infrastructure,
but its delivery has to be joined up with the creation of new parts of
4.12 The creation of an urban extension to the south west of Bristol has been the subject of a sustainability appraisal and of extensive and intensive stakeholder and public engagement. The Draft RSS features a proposal for the urban extension, and the emerging RSS has been subject to
sustainability appraisal at every point in its preparation to date as well as Appropriate Assessment under the Habitats Regulations. Consultation has taken place on the emerging RSS and has been integral to the preparation of the Core Strategy so far. Notably, the Council produced an explanatory broadsheet and consulted widely on the conceptual and spatial options for
the development of an urban extension to south west Bristol as an Issues
and Options stage in the preparation of the Core Strategy in October 2007.
Included as part of this Issues and Options stage in its programme of
engagement was a stakeholder workshop in which 110 people took part
over two 2-day facilitated events during April 2008. The Planning Together
event is referred to in the consultation document. The consequence of this
together with other responses during this consultation stage was that the
Council has only carried forward into subsequent stages of work an urban
extension of Bristol as the means of achieving the strategic development
required at Bristol, discounting such as the creation of a substantially
separate new settlement or major extensions to such as Failand. The
'diagram' of the form this development might take that emerged from the
Planning Together workshop with general consensus is broadly similar to
the development LandTrust is proposing. The development used land at
Ashton Vale but not the land south of Long Ashton for instance.
4.13 No significant objection on planning grounds to the south west Bristol urbanextension has ever been presented allied to a realistic and preferable means of meeting the development requirement. The dissatisfaction with the longstanding proposal for this development has been from parties who believe that it is not for plans to seek to provide for future needs of communities or has been politically driven based on the historic accident of the location of administrative boundaries. Objections have been made on green belt grounds, but all of the land on the edge of Bristol is within the green belt and the continued growth and development of Bristol necessitates a change to the extent of the designated green belt.
4.14 The evidence leads to the requirement for and the appropriateness of an urban extension to the south west of Bristol.