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 11224833//2
Respondent Deleted User [View all comments by this respondent]
Agent IJP
Response Date 28 Apr 2016

1.1 This representation has been prepared by Ian Jewson Planning Ltd on behalf of Land Value Alliances (LVA) and relates to the Consultation Draft of North Somerset Council’s (NSC’s) Site Allocations Plan (SAP). The representation comments on both the general approach of the document and specifically to Site Allocations at Nailsea. Reference is also made to land North of Nailsea which is controlled by LVA and has previously been promoted for mixed use development during earlier stages of North Somerset Council’s (NSC’s) consultation process.

1.2 The representation will demonstrate that the Consultation Draft of the Site Allocations Plan is premature as it is based upon the LPA’s proposed changes to the remitted policies of the Core Strategy. These changes have not yet been though examination and are subject to a significant level of objection, primarily on the basis that they are not ‘justified’, one of the four tests of soundness set out in the National Planning Policy Framework (NPPF).

2. Prematurity

2.1 Page 9 of the Consultation Draft SAP sets out the latest position in respect of the Core Strategy which is said to provide the context for preparing the Site Allocations Plan. The key points being:

  • The Core Strategy was adopted in April 2012. Policy CS13 (Scale of New Housing) set a housing requirement of 14,000 dwellings for the period 2006 and 2026. However, following a legal challenge by the University of Bristol the policy was remitted back to the Planning Inspectorate for re-examination. Following the re-examination and an intervention by the Secretary of State the housing requirement for the plan period was increased to 20,985 dwellings in September 2015.
  • The increase to the housing requirement has implications for eight other policies in the Core Strategy. These policies were also remitted back to the Planning Inspectorate for re-examination. The policies are:
    • Policy CS14 (Distribution of New Housing)
    • Policy CS6 (Green Belt)
    • Policy CS19 (Strategic Gaps)
    • Policy CS28 (Weston-super-Mare)
    • Policy CS30 (Weston Villages)
    • Policy CS31 (Clevedon, Nailsea and Portishead)
    • Policy CS32 (Service Villages)
    • Policy CS33 (Infill Villages, Smaller Settlements and Countryside)

NSC consulted on their proposed modifications to the above policies between 6th November and 18th December 2015. The LPA have forwarded the responses to the Planning Inspectorate who have appointed an Inspector to examine them.

2.2 NSC then describe the relationship between the Core Strategy and the Site Allocations Plan and advises that:

"Taking into account completions and existing commitments, the Site Allocations Plan only needs to identify sites for 1,715 dwellings in order to ensure that the housing requirement of 20,985 dwellings is achieved. The Site Allocations Plan has been prepared in accordance with the LPA’s proposed changes to the remitted policies".

2.3 It is premature for NSC to prepare a Site Allocations Plan that is based on the above assumptions. There have been significant objections to the LPA’s proposed changes to the remitted policies of the Core Strategy and they have not yet been subject to examination. The key objections include:

  • The proposed increases to the dwelling requirements for the various settlements have not been justified.
  • It is not considered that NSC’s evidence on future housing delivery is properly justified. For example, the consultation document for the remitted policies advises that 589 dwellings will be delivered on ‘Other Identified Sites’, However, no information has been provided on the location or deliverability of these sites (simply that they are brownfield).
  • The consultation document for the remitted policies does not assess whether the Council’s employment-led approach to development (1.5 jobs per dwelling) in Weston-super-Mare and the Weston Villages remains achievable when taking into account the increased housing numbers.
  • It is not considered that NSC has properly explored or tested whether or not it will be necessary to release land from the Green Belt to help meet the increase housing requirement.
  • It is not considered that NSC has properly considered the ability for Nailsea to accommodate future housing and employment growth to help meet the increase housing requirement.
  • NSC has not considered any alternative distribution scenarios.
  • There has not been a Sustainability Appraisal of the proposed changes to the remitted policies.

2.4 These concerns are shared by the Inspector that has been appointed for the examination on the Core Strategy remitted policies, as evidenced by both his letter to NSC on 24th February 2016 (Appendix 1, attached) and his choice of matters to be discussed at the examination in June (Appendix 2, attached). It is considered likely that the proposed changes will be either found unsound or require significant further amendments. On this basis work on the Site Allocations Plan should be halted until the remitted polices have been adopted and the distribution strategy for new housing has been finalised.