Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation MM16 [View all comments on this section]
Comment ID 16123553//2
Respondent Deleted User [View all comments by this respondent]
Agent GL Hearn (Henderson)
Response Date 30 Oct 2017

The Inspector’s letter (ID4) set out that the SAP Publication Version would fail to deliver the Core Strategy housing requirement, or ensure North Somerset Council could maintain a 5 year housing land supply.

To address this the Inspector expected the Council to test the potential for the provision of up to 2,500 additional houses. The Council’s response to the Inspector’s letter has been to test potential housing allocations, including sites which are "broadly consistent with the Core Strategy spatial strategy", from which the Council proposes the allocation of an additional 821 residential units.

This falls significantly short of the target expressed by the Inspector, does not provide the required significant buffer between the Core Strategy requirement and provision within the SAP and is unlikely to address the fundamental concerns that the SAP will fail to deliver the Core Strategy housing requirement to 2026 or to ensure that the Council can maintain a 5 year housing land supply. This is illustrated by the Council’s evidence set out by CD4a, dated September 2017, which indicates a 5 year housing land supply (2017/18 to 2021/22) of 9149 dwellings, or 4.8 years. That in itself determines that the plan cannot be found sound.

It is also evident that in reaching its proposed additional 821 dwellings, the Council has not exhausted all sources of potential housing supply. The Council’s assessment criteria, outlined by the Inspector at paragraph 24 of ID4, include "sites which area broadly consistent with the Core Strategy spatial strategy". These sites are listed at CD2a and include Old Mill Road, Portishead.

As part of the Council’s site assessment process, SLI submitted information (June 2017) to the Council confirming arrangements to bring the site forward (for mixed-use development, including 350 dwellings) and the anticipated build rate trajectory for the proposed residential element of the redevelopment proposal.

Further comments were provided to the Council in August 2017, in response to the Council’s ‘Further Residential Site Assessment’ consultation. That response challenged the Council’s assessment that ‘retention of existing businesses’ was a key constraint to the residential potential of the site, and re-confirmed SLI’s desire to engage with the Council through the development management process to bring forward detailed development proposals, including a significant residential element alongside commercial town centre uses.

The main modification (MM16) to amend the wording of Schedule 1 by replacing "a small amount of residential" with "some residential", does not reflect the residential suitability and potential of the site and, critically, appears to be a modification designed to try and accommodate the town centre site’s in principle suitability for residential use without contradicting the Council’s employment (Class B1–B8) policy stance set out MM2.

Additionally, the term ‘some residential’ although undefined, is likely to be applied in the context of its usual meaning and therefore be interpreted in practice as substantially less than 350 units (or the potential residential capacity of the site to be established following engagement with Council through the development management process). This likelihood is strengthened by the proposed modification within Column 4 of Schedule 1 ("Capacity remaining (at April 2017)") which proposes identifying ‘zero’ capacity for the Old Mill Road site.

The Council’s justification for MM16 is provided by the Council’s Executive (5th September 2017), the officer’s report for which outlines that the provision of 350 residential units at the site, as part of a redevelopment proposal, was not supported "given the need for any redevelopment to accommodate existing businesses on the site" and that there was "no convincing evidence that this is deliverable in 5 years" (NSC Report to the Executive, 5th September 2017).

In respect of the site’s exclusion on the grounds that redevelopment of the site will "need" to accommodate existing businesses on the site, this requirement is not substantiated by any evidence and can be considered contrary to adopted policy (see comments in respect of MM2 above). In any event, the Council’s proposed Schedule 1 text does not require existing businesses to be accommodated on the site, but rather also accepts the potential for existing businesses to be relocated.

The conclusion of the Council in respect of the deliverability of the site is not supported by any evidence and is contrary to the evidence provided by SLI in response to the Inspector’s request (paragraph 25 of ID4) for the Council to work closely with the development industry to identify potential opportunities for additional residential development.

The residential potential of the Old Mill Road site should not be limited by arbitrary and unsupported judgements about the potential capacity of the site, or by the use of terminology that in its normal meaning will imply considerably fewer residential units than the site can, and should, provide. Rather Schedule 1 should recognise the suitability and potential of the site to make a significant contribution to identified housing requirements, as part of a mixed-use development, in line with national and adopted policy.