Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation 1. General comments [View all comments on this section]
Comment ID 17440577//1
Respondent Highways England [View all comments by this respondent]
Response Date 01 Nov 2017

I refer to the public consultation on the Proposed Modifications to the North Somerset Site Allocations plan. Set out below is Highways England’s formal response to the consultation.

Highways England has been appointed by the Secretary of State under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network. Within North Somerset, the Strategic Road Network comprises the M5 motorway.

The Strategic Road Network is a critical national asset and Highways England is responsible for ensuring that it operates and is managed in the public interest, both in respect of current activities and needs, and in providing effective stewardship of its long- term operation and integrity.


Highways England policy relevant to the acceptability of new developments is set out in Department for Transport Circular 02/2013 – "The Strategic Road Network and the Delivery of Sustainable Development". Paragraphs 9, 10 and 11 of the Circular summarise the correct approach to development proposals as follows:

"9. Development proposals are likely to be acceptable if they can be accommodated within the existing capacity of a section (link or junction) of the strategic road network, or they do not increase demand for use of a section that is already operating at over-capacity levels, taking account of any travel plan, traffic management and/or capacity enhancement measures that may be agreed. However, development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

10. However, even where proposals would not result in capacity issues, the Highways Agency’s prime consideration will be the continued safe operation of its network.

18. Capacity enhancements and infrastructure required to deliver strategic growth should be identified at the Local Plan stage, which provides the best opportunity to consider development aspirations alongside the associated strategic infrastructure needs".

Applying the principles of paragraph 9 of Circular 02/2013, development proposals are likely to be unacceptable, by virtue of a severe impact, if they increase demand for use of a section that is already operating at over-capacity levels, or cannot be safely accommodated, ie, a development which adds traffic to a junction which already experiences road safety issues; would increase the frequency of occurrence of road safety issues; or would in itself cause those road safety issues to arise, would be considered to have a severe impact.

These principles are reflected in the NPPF which (at paragraph 162) requires that local planning authorities should work with other authorities and providers during the plan making process to assess the quality and capacity of infrastructure for transport and its ability to meet forecast demands.

The aim of this cooperation is to arrive at a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development. (NPPF paragraph 181).

Pursuing sustainable development requires careful attention to viability and costs. The sites and the scale of development identified in the plan should not be subject to such a scale that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as infrastructure contributions or other requirements, should provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. (NPPF paragraph 173)

It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. (NPPF paragraph 177).

In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe. (NPPF paragraph 32).

For the Plan to satisfy the requirements of NPPF it would therefore need to be supported by an assessment of the infrastructure necessary to ensure that traffic impacts are not severe. Highways England would be content with the proposed allocations if the identified infrastructure satisfied the requirements of Paragraph 9 of Circular 02/2013.

The Local Highway Authority will have their own criteria and it should also be noted that the requirements of the Plan, in terms of providing the necessary housing, may require additional infrastructure to be identified, particularly in relation to existing issues which would be beyond the remit of Highways England to consider.

The Plan

The purpose of the Site Allocations Plan is to deliver the key policies set out in the Core Strategy. These include:

-the housing needed within North Somerset;

-policies related to the delivery of additional employment growth;

-policies that will protect the environment; and

-provide additional facilities for leisure and social and community uses.

Proposed Modifications consultation

On first review of the consultation information available for this Proposed Modifications consultation, Highways England noted that there was no update to the ‘NSC response to Matter 4 – Transport’. This note had been produced in response to Highways England’s letter dated 19th December 2016 that noted that ‘none of the evidence base documents referred to in Section 3 of the Plan relate to highways or transport infrastructure and no further evidence base documents have been published to support this consultation’.

The omission of an update was bought to the attention of North Somerset Council and an addendum to the ‘NSC response to Matter 4 – Transport’ was added on 23rd October 2017 and the updated version of the ‘NSC response to Matter 4 – Transport’ note sent to Highways England on 25th October 2017.

The response below has been prepared in response to the addendum assessment.

Transport Evidence Base - addendum

The addendum to the Transport Evidence Base notes that Highways England accepted the original assessment at the public hearing held on 18th May 2017.

The addendum assessment considers the additional 821 dwellings that have been allocated as a result of the Inspector’s comments. The assessment identifies that the 821 dwelling increase is a 4% increase on the original total, and that the new sites were dispersed across the district. The original assessment undertaken reported that the impact of sites on the SRN was not significant. The addendum assessment says that the relatively small increase in dwelling numbers and the dispersed nature of their origin does not change the original conclusion that the impact is not significant.

Highways England assessment

Highways England accepts that the increase in housing numbers is relatively small (4%), and that the location of the sites is dispersed. Reviewing the locations of the new site allocations, it is noted that there is a larger proportion of new sites are in the vicinity of Weston-super-Mare, Clevedon and Portishead. All these locations have access to the M5. There are, though, allocations further afield in Nailsea, Winscombe and Churchill. These sites have relatively poor access to the M5 and alternative routes to Bristol. Hence, Highways England agrees that the sites are dispersed, albeit with a bias towards the M5 corridor.

As the original note describes, there are a number of highway improvement schemes being promoted by NSC and Highways England to upgrade the key approach roads to M5 Junctions 19 and 21. These schemes will help the accommodation of growth. It is noted that there has not been any detailed assessment presented of the capability of these schemes to accommodate the forecast growth from the modified plan. However, the detailed assessment of each site will be considered on its own merits.

On balance, and mindful of the likely impact in any one location and whether this impact would constitute a severe impact, the need to undertake a proportionate assessment for the scale of impact has guided the conclusion drawn by Highways England. The conclusion drawn is that the additional growth identified in the Modifications for the Plan does not change the original view that the impacts of the proposed allocations, when the identified schemes are in place, do not constitute a severe impact on the SRN.

I hope you find the above useful. If there are any queries or matters raised above which would warrant additional discussion then please contact me on the telephone number at the head of this letter.