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 14402625//5
Respondent Deleted User [View all comments by this respondent]
Agent Taylor Wimpey - Turley Associates
Response Date 28 Apr 2016

These representations are made regarding the draft Site Allocations Plan and are submitted by Turley on behalf of Edward Ware Homes Ltd who have interests in land at Wrington. Attached is a site location plan showing the extent of the land that our clients control.

The site adjoins the settlement boundary of Wrington along three of its site boundaries, and is to the west of Garstons Orchard, a residential area at the south of the village. The site forms a break in the built form at the south of the town, residential development of this area would therefore sit well within the existing form of the settlement, particularly given that the adjoining land uses are currently primarily residential to the west, north and east. The site is within a conservation area, however, it is on the edge of this designation and adjoins modern development to the east. A sensitively designed scheme could address any heritage impact and enhance this outer edge of the conservation area through sympathetic design.

The site is subject to few environmental constraints, although part of the eastern area is within flood zones 2 and 3 this appears to be localised flood risk adjoining a small watercourse which adjoins the site and extends into the village. The site is also within a Bat Habitat area, although this designation also covers the entirety of the adjoining settlement. The site is relatively flat and, unlike other potential growth areas to the north and east of the village is not constrained by Green Belt. The site is capable of delivering circa 40 units suitable of meeting the future housing requirements of the District without having adverse impact on the landscape setting of the village or involving any loss of Green Belt.

Sites and Policies Plan Part 2; Site Allocations Plan

The Sites and Policies Plan Part 2; Site Allocations Plan to which these representations relate proposes to allocate sites to achieve the development set out in the Core Strategy. Our client’s site is in a sustainable location adjoining the settlement boundary of a Service Village and should, therefore be included as a residential allocation in this Plan to contribute to meeting the housing requirements of the District.

In the light of the above, we would therefore request the following policy revisions;

Policy SA1 of the draft Allocations Plan sets out the purpose of the settlement boundaries as shown on the Proposals Map. The Proposals Map shows the existing settlement boundary of Wrington as excluding our client’s site despite the fact that the boundary nearly entirely encases the site. As can be seen from the Proposals Map extract below, to extent the boundary to include this site would enable development in a very logical location in relation to the existing built form of the settlement.

Figure 1 – Extract from the proposals map showing Settlement Boundary and site outlined in red

Policy SA2 refers to the allocation of residential sites of 10 or more units; it refers to Schedule 1 which details all large sites of 10+ dwellings included within the Council’s supply. Schedule 1 does not, however, include any residential sites at Wrington. Given the need to meet the housing requirements of the District we would suggest that this sustainable site, outside of the Green Belt, at sustainable location should be considered for development.

Status of the Site Allocations Plan

The purpose of the Site Allocations Plan is to identify detailed allocations required to deliver the Core Strategy. However, several policies, importantly including policies relating to the distribution of new housing, remain remitted following the legal challenge to the plan in 2013. Although the Council now have a revised adopted housing requirement (20,985 dwellings between 2006 and 2026) remitted policies to govern how this requirement will be distributed have not yet been re-examined.

The Council describe the Site Allocations Plan as ‘a transitionary plan’ given that the Core Strategy will be reviewed by the end of 2018. However, the conclusion of the re-examination of the remitted policies is unknown and hearing sessions on this are not programmed until June 2016. We would question whether the Site Allocations Plan can be brought forward at this time given the extent of the uncertainty surrounding the re-examination of key elements of the Core Strategy.

Furthermore the West of England Local Authorities are currently collaborating to prepare the Joint Spatial Plan, the distribution of the additional housing allocations between the authority areas has not been established. This joint plan must ensure the region’s growth is accommodated in sustainable locations: - given that the ‘share’ of growth to be accommodated within North Somerset has not been determined there is a real danger that sites brought forward through this Site Allocations Plan ahead of these decisions will simply not be sufficient. This provides greater justification for the positive allocation of appropriate sites that seek to take a longer term and proactive approach to meeting both current and future housing needs.

Housing Requirement and Housing Supply

The revised adopted housing requirement for the district is a minimum of 20,985 over the plan period as confirmed by the Secretary of State in September 2015. As set out in the draft Allocations Plan 7,426 dwellings have already been completed over the plan period from April 2006 to April 2015. This leaves a residual requirement of 13,559 to be identified to 2026. Furthermore this figure is expressly stated to be a minimum requirement, it would be prudent for the Council to treat this figure as a minimum and ensure that potential delays and non-implementation of sites does not result in a lack of five year supply or indeed, under delivery across the plan period. Consequently, in line with the NPPF’s requirement to boost significantly the supply of housing and to maintain delivery of five-year supply the Council should be allocating a greater amount than the minimum required in the Site Allocations Plan.

At Table 1 of the draft Allocations Plan the Council states that it has a total commitment figure of 21,114 dwellings over the plan period. However this is just 219 above the minimum requirement and, as set out below the claimed sources of this supply are not fully and robustly evidenced.

Table 1 of the draft Allocations Plan identifies a total potential supply (including completions to date) of 21,114 dwellings. 1,200 of these are from windfalls; the table states that the figures are based on past rates and on page 14 the draft Plan gives the following explanation ‘windfall sites are sites which have not been specifically identified as available but based on past building rates will come forward over the remainder of the plan period’. This is the only apparent evidence given for the inclusion of this level of windfall and it is not sufficient justification for this figure. In line with the NPPF (paragraph 48) authorities should only include windfall sites in the five year supply if they have compelling evidence that such sites will become available. No such compelling evidence has been provided and this level of windfalls should not be relied upon.

Table 1 also includes 225 units contributed to the supply from ‘other large sites with consent (not proposed to be allocated)’. The explanation of what this category of supply comprises states that these are sites that are expected to be built out before public consultation of the document and those with a permitted development change of use consent that would otherwise be contrary to policy. These sites are not however clearly distinguished at Schedule 1 and it is not clear whether an appropriate non-implementation discount has been applied to them. Without such clarity we would question the justification for relying on this level of supply from this source.

Schedule 1 also details several sites, without a current consent, carried over from the North Somerset Replacement Local Plan. These sites make a substantial contribution to the Council’s claimed supply; for instance Westacres Caravan Park is stated as having capacity of 100 units, and Land north of the A370 with a capacity of 80 units, however these sites do not currently have planning consent and it is not therefore certain that these sites will come forward. Furthermore, these sites have been carried over from the previous Local Plan which was adopted nearly 10 years ago, in 2007, given that these sites have been allocated for a significant amount of time with no development coming forward, the Council should not be continuing to rely on their contribution to its overall housing needs.

The Council also, at Schedule 1, include contributions from C2 unit schemes including, for example, 124 units from a proposed care village at Redwood Lodge. However, the PPG (reference ID 3-037-20150320) states that:

“Older people have a wide range of different housing needs, ranging from suitable and appropriately located market housing through to residential institutions (Use Class C2). Local planning authorities should count housing provided for older people, including residential institutions in Use Class C2, against their housing requirement. The approach taken, which may include site allocations, should be clearly set out in the Local Plan.” (emphasis added)

In North Somerset, the approach to be taken to older people is not clearly set out in the Core Strategy as required by PPG. It is not clear whether the overall housing requirement in the Core Strategy of 20,985, includes provision for the specific needs (and number of C2 units/beds) required for older persons. Unless the Council is able to specifically identify that the full needs for older persons are accommodated within the overall housing requirement and until such time as the approach taken is clearly set out in a local plan (which it is not either in the Core Strategy or in the draft Part 2 Plan) then sites which will provide C2 units should not be included as counting towards the Council’s overall housing requirement.

Given that the Council have made generous assumptions on what level of the identified sites will actually contribute to the supply, that windfalls have been relied upon, that no apparent non-implementation discount has been applied, that old local plan sites are carried forward despite concerns about delivery, that C2 uses are shown as contributing to supply and that the housing figure is a minimum only; we would suggest that the Council should plan to delivery more than a mere 219 additional units above the minimum figure over the plan period. Sites such as our client’s land at Wrington that are sustainable, developable and sustainable should be allocated for development.

Suitability of the Sites for Development

The adopted North Somerset Core Strategy identifies Wrington as a Service Village, which benefits from a range of existing services and facilities. Although the policies relating to the distribution of development within the District have been remitted, Wrington remains a sustainable Service Village to accommodate growth.

Appendix 1 to the Sustainability Appraisal which comprises part of the consultation documents accompanying the draft Allocations Plan contains the individual assessment of residential sites put forward for development by developers. Our client’s site was considered as an area detailed as ‘South of Wrington’ (site ref. NS0120) for which the conclusion was that the site should not be allocated for housing in the Site Allocations Plan. Despite only scoring red on two of the categories assessed, the reasons given for not allocating the site was that it would intrude into the rural setting of the village and that roads in the village are too narrow. For the reasons set out below, we disagree with this assessment.

In the assessment site ref. NS0120 scored green on 4 categories, amber on 10 and red on only 2. The red categories were ‘PDL/Greenfield’ and ‘sustainable transport’. Criteria 4.4 relates to previously developed land and we accept that as the site is green field it complies with the red scoring for this category. Criteria 5.1 however relates to reasonable access to sustainable transport, a red score for this category is defined as ‘poor links to the surrounding area/poor transport provision’ and an amber score; ‘connection to the surrounding area and public transport provision could be improved’. We suggest that amber would be a more appropriate scoring for this site given that the A2 bus passes through the village providing hourly services to Weston-Super-Mare and that a Strategic Cycle Route also passes through the village.

There are no public rights of way within the site and no public access to this area. A small scale scheme of circa 40 units could enhance this area by providing an element of public open space including potentially allowing public access to the river area.

Overall the site is suitable for development, the Council’s assessment of the site considered that it has a capacity of around 40 units and it is in a sustainable location adjacent to the settlement boundary of a service village. Development of the site would not intrude into the surrounding countryside or affect the rural setting of the village as there is existing development along three sides of the site currently, as identified on Figure 1 above the site would fit well logically into the existing settlement form and deliver much needed housing in this village.


The potential for the site to deliver around 40 dwellings is development of an appropriate scale for this settlement which would make efficient use of each site and fit well into the surroundings. The development of this site would result in benefits to the local community in the form of high quality new homes, including affordable housing, support for local services and the creation of public open space.

The identification of sites which are suitable, available and deliverable is important to ensure that housing needs are met, as well as supporting community infrastructure. This site is suitable, available and deliverable.