Site Allocations Plan March 2016

Document Section Site Allocations Plan March 2016 PUT FORWARD A SITE OR MAKE GENERAL COMMENTS Put forward a site [View all comments on this section]
Comment ID 11199745//6
Respondent Gladman Developments Ltd [View all comments by this respondent]
Response Date 03 May 2016

1.1          Housing Allocations

      1. Notwithstanding the issues raised above in this representation about the scale of the shortfall in housing numbers that need to be allocated in the Site Allocations Plan (1,715 units), Gladman also has concerns about a number of the Housing Allocations made in the Plan.
      2. Rather than going into detail about each individual site that is contained within Schedule 1 of the Plan (Sites proposed for residential development), this representation concentrates on key overarching issues affecting a number of the sites that may bring into question the speed of delivery of a site or its suitability for allocation.
      3. 75% of the proposed allocations and large sites with Planning Permission are located within Weston-super-Mare, a town that has struggled to deliver new housing growth in the past because of commercial viability and may not deliver units as quickly as the Council have suggested going forward because of issues of market saturation. A large number of units proposed in Weston-super-Mare are on large scale Sustainable Urban Extensions (SUEs). Over 6,500 units are proposed on two SUEs that are covered by a variety of consents ranging from no consent, to part outline or part full.
      4. Research undertaken recently by Savills on the delivery of SUEs on behalf of Barratt Homes (Appendix 5) concludes that on average, across all sites analysed, an urban extension site starts construction on the first phase of housing more than four years after the submission of an outline application. Analysis of the sites in the sample indicates that, once construction starts and in a strong market, annual delivery can be anticipated to be around 60 units in first year of construction, picking up to more than 100 units per annum in subsequent years and increasing to around 120 units. It should be noted that the above timescales do not take into account:b) Pre application discussions/negotiations and preparation of the outline planning application
      5. c) The period between starting construction and delivering the first residential unit
      6. a) Time taken between the allocation of the site and starting preparation of the planning application
      7. On the basis of the issues highlighted above in terms of lead-in-times, delivery rates and market conditions, Gladman raise considerable concern with the deliverability of the Weston-super-Mare SUEs.
      8. In addition, several of the allocations in Weston-super-Mare require large scale regeneration, the demolition and conversion of buildings within the Town Centre, as well as the potential relocation of some uses and remediation work to address potential contamination. These types of schemes are complex and difficult to deliver for a whole number of reasons and should be treated cautiously by the Council when considering delivery trajectories associated with the sites. Some of the proposed allocations are also located in Flood Zone 3, therefore requiring both a Sequential and Exception Test to be carried out before they can be determined to be deliverable. Guidance in the Framework states that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas of highest risk.
      9. A Habitats Regulation Assessment of the Site Allocations Plan is also required and the Council have identified that this will be finalised at the Publication Plan stage. The outcome of this study may have implications for some of the allocations and subsequently for the delivery of the Plan.
      10. The Site Allocations Plan will also have to be updated to reflect recent planning approvals for example at Cobthorn Way, Congresbury where the capacity of the site is listed as 54 dwellings but the Council recently resolved to grant permission subject to a Section 106 agreement for a scheme of 38.
      11. In terms of the geographical spread of new development across the district, Gladman have already commented on the disproportionate amount being directed towards Weston-super-Mare. However, Gladman are also concerned that there are a number of Service Villages, that are not constrained by Green Belt, which are identified in the Core Strategy where no growth is being directed across the whole Plan Period including Banwell, and Wrington. These settlements are experiencing an aging population and without future development, this can only be exacerbated with the potential consequences of falling school registers and a lack of support for local schools and facilities.
      12. It is considered that any residual housing requirement that is found to be needed as a result of the increase in the Core Strategy Housing target should be directed to sustainable and deliverable housing sites within the Service and Infill Villages. This is to ensure a deliverable 5-year housing land supply prior to the Weston-super-Mare SUEs coming on stream, to provide much needed market and affordable housing for local communities that live in or have links to these villages and to provide essential support to the services and facilities within these settlements.
      13. Gladman have a number of sites that are being promoted through the planning process within the Services Villages and Infill Villages that are sustainably located, deliverable and without constraint. The sites are located in Banwell, Congresbury, Claverham and Locking and all offer the opportunity to deliver units in the short term to contribute to the Council’s deficient 5-year housing land supply and provide much needed homes for local people. The sites detailed below with associated relevant information are included as Appendices to these representations.
      14. Land south of Knightcott Road, Banwell (Appendix 1)
      15. Land north of Chestnut Drive, Claverham (Appendix 2)
      16. Land off Wrington Lane, Congresbury (Appendix 3)

Land at Elm Grove Nursery, Locking (Appendix 4)