Site Allocations Plan March 2016

Document Section Site Allocations Plan March 2016 Introduction Purpose of the document [View all comments on this section]
Comment ID 11199745//1
Respondent Gladman Developments Ltd [View all comments by this respondent]
Response Date 03 May 2016


  1. Gladman Developments specialise in the promotion of strategic land for residential development with associated community infrastructure. This submission provides Gladman Development’s representations on the North Somerset Site Allocations Plan Consultation Draft 2016.
  2. Through this submission Gladman have highlighted a number of significant issues with the North Somerset Site Allocations Plan in its current form.
  3. To ensure a sufficient supply of deliverable and developable sites and to meet North Somerset’s objectively assessed needs in full, we submit that the plan should be seeking to direct the growth to a broad range of sites located across all the sustainable settlements in both urban and rural areas across the district in order to provide greater certainty that housing will be delivered.
  4. The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard we submit that in order to prepare a sound plan it is fundamental that it is:
      • Positively Prepared – The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
      • Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base.
      • Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
      • Consistent with National Policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

Legal Compliance

2.1 Duty to Cooperate

  1. The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan preparation. As demonstrated through the outcome of the 2012 Coventry Core Strategy Examination and the 2013 Mid Sussex Core Strategy Examination, if a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.
  2. Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration[1], as set out in the PPG it is clear that it is intended to produce effective policies on cross-boundary strategic matters. In this regard North Somerset must be able to demonstrate that it has engaged and worked with neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily address cross boundary strategic issues, and the requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question of effective cooperation.
  3. Further the PPG reflects on the public bodies which are subject to the duty to cooperate. It contains a list of the prescribed bodies. The PPG then goes on to state that:

“These bodies play a key role in delivering local aspirations, and cooperation between them and local planning authorities is vital to make Local Plans as effective as possible on strategic cross boundary matters.”


  1. Through this submission Gladman have highlighted a number of significant issues with the North Somerset Site Allocations Plan in its current form. The planning policy picture in North Somerset remains complicated. The Council is currently preparing three Development Plan Documents (DPD) and Gladman have been actively involved in the various stages of consultation on all of the documents stretching back to 2013. The Council will therefore be aware that there remain outstanding objections from Gladman with regard to all elements of the Local Plan.
  2. Gladman are concerned with the piecemeal approach that North Somerset is taking with the preparation of the Local Plan. The remitted policies of the Core Strategy are being progressed separately from the Sites and Policies Plan Development Management Policies and separately from the Site Allocations Plan. This approach seems confusing, disjointed and has the potential to alienate people and dissuade them from becoming involved in the process. The whole of the Sites and Policies Plan should have been progressed as one comprehensive document including Development Management Policies and Site Allocations.
  3. Gladman are surprised that the Council are continuing to progress a Site Allocations Plan at this stage before the remitted policies of the Core Strategy have been examined and found to be sound. There is considerable outstanding objection to the remitted policies, including concern that the Council consider that the residual housing requirement to be allocated in the Site Allocations Plan, following an increase in the Council’s overall housing requirement from 14,000 to 20,985, is only 1,715 units.

[1] PPG Reference ID. 9-011-2014036