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 14859969//3
Respondent Deleted User [View all comments by this respondent]
Agent IJP
Response Date 28 Apr 2016

2. Prematurity

2.1 On page 9 of the Consultation Draft the LPA set out the latest position in respect of the Core Strategy which provides 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 in 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)
  • The LPA 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 The LPA then describe the relationship between the Core Strategy and the Site Allocations Plan and advise 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 In response IJP submits that it is premature for the LPA 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 on a number of issues. These include the distribution of the increased housing requirement across the various settlements, the LPA’s evidence on future housing delivery, and the lack of a Sustainability Appraisal to support the consultation document for the remitted policies. And as previously stated the remitted policies have not yet been subject to examination.

2.4 Further, a number of the concerns raised are shared by the Inspector who has been appointed for the examination on the Core Strategy remitted policies, as evidenced by both his letter to the LPA of 24th February 2016 and his choice of matters to be discussed at the examination in June. It is considered that in all probability 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.