Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation MM38 [View all comments on this section]
Comment ID 11199745//1
Respondent Gladman Developments Ltd [View all comments by this respondent]
Response Date 30 Oct 2017

Strategic Gaps


This representation is an individual response submitted by Gladman Developments Ltd (Gladman) to the current consultation on the Main Modifications of the Sites and Policies Plan Part 2: Site Allocations Plan (SAP). Public consultation commenced on 18th September and closes on 30th October 2017.

This representation deals with the issue of Strategic Gaps only. Gladman have previously submitted evidence on this issue within their Matter 5 (Local Green Space and Strategic Gaps) Hearing Statement to the SAP Examination and also provided oral evidence on this matter at the Hearing session on 18th May 2017.

The Inspector’s Post Hearing Note to the Council (ID-4) responds to the urgent need for North Somerset to identify additional housing to ensure there is confidence that the adopted housing requirement will be met in full by 2026. The Inspector requires additional sites to conform broadly to the Core Strategy spatial strategy and provide a wide choice of sites, the outcome of which would inevitably be a requirement to seek positive opportunities for growth on the edge of the larger settlements, including within strategic gap. The Council, within their main modifications, have still failed to achieve this goal.

Strategic Gaps are not supported by the NPPF, they are not an ‘environmental’ designation and certainly are not they type of designation protected by NPPF 14 footnote 9. They do not preclude land from benefitting from the presumption in favour of sustainable development. Their role in North Somerset, in terms of shaping a sustainable pattern of development, has not been properly tested or justified.

The opportunity existed for the Council to consider the merits for the proposed Strategic Gaps and realise the opportunities that existed for sustainable development in those areas so they achieve their housing goals. The negative approach, ruling out the positive consideration of land within gap (the principle of which was justified many years ago, against now out-dated planning policy and housing requirements) is an approach that is unjustified and ineffective. It is not sound, it is stifling the district and preventing the Council from achieving their modest goals for sustainable development outlined the Site Allocations Plan.

Post Submission of Hearing Statements to SAP Examination

Prior to the Hearing sessions commencing, the Council published a retrospective Sustainability Appraisal for the Strategic Gap designations (CS13 Council Statement Matter 5.4). This document was tailored to fit with the Council’s published draft policies and clearly failed to consider reasonable alternatives. The alternatives considered on this topic are ‘SAP allocation’ or ‘No Plan’. This is not acceptable and fails to adequately justify the imposition of such a policy. As a consequence, the plan as proposed to be modified remains unsound.

SCI (Meet Housing Requirement) states that there would be a ‘neutral effect’ because the SAP makes sufficient allocations to meet the housing requirement. The Council acknowledge in CD4a (September 2017) that they cannot demonstrate a five-year housing land supply (4.8 years) - a shortfall of 375 dwellings on their own five-year deliverable supply. Using the development industry consortium’s five-year deliverable supply figures, the shortfall is significantly greater at 3,421 dwellings (3.2 years).

At the hearing sessions held in May 2017, the matter of Strategic Gaps was not fully explored as it had become quite apparent that the Council had failed to develop a plan that positively planned for housing in the area. Whilst the Inspector, in requiring the allocation of additional housing sites, notes the environmental constraints in the district and a number of environmental/technical factors that will slow down the delivery of allocated sites, she does not, in any way, suggest that land within strategic gap should be ruled out. Conversely, she requires additional sites to conform broadly with the Core Strategy spatial strategy and provide a wide choice of sites, the outcome of which would inevitably be a requirement to seek positive opportunities for growth on the edge of the larger settlements, including within strategic gap. Significantly, the NPPF calls for:

      • Local planning authorities to seek opportunities for sustainable development avoiding adverse impact on the three dimensions of sustainability and where possible pursue alternative options which reduce or eliminate negative impacts (NPPF 152).
      • The plan to be justified with reference to reasonable alternatives (NPPF 182).

Strategic Gap between Weston-super-Mare, Locking and Parklands Village

The Strategic Gap between Weston-super-Mare, Locking and Parklands Village has been amended to include land to the south of the existing designation, the static homes on Fir Tree Avenue and Oaktree Parks. The Council maintains in MM38 that this is a logical southern extension of the part of the strategic gap between Oaktree Parks Ltd and Locking and would help to retain the separate identity, character and landscape setting of the settlements.

It is unclear why the Council now considers that adding a spur to the south of the existing Weston-super-Mare, Locking and Parklands Village Gap is necessary or sound. There is no explanation in any of the supporting evidence to justify this amendment.

The Council undertook a detailed review into the boundaries of the proposed Strategic Gap in October 2016. In respect of the gap between Weston-super-Mare and Hutton, no alterations were proposed save for an extension to the west to allow it to abut the settlement boundary of Weston. The land put forward in the February 2017 extension was not even considered. In respect of the gap between Weston-super-Mare, Locking and Parklands Village, no alterations were recommended and the report specifically stated:

‘Taking account of the above, there is no identified need to amend the boundaries of this strategic gap.’

Gladman strongly objects to the proposed amendment to include land east of the Oaktree Caravan Park and west of the former Elm Grove Nursery site. Gladman’s outline application on Land at Elm Grove Nursery, Locking (application ref: 15/P/1205/O) was refused in March 2017, with the first reason for refusal stating the development of this site would cause coalescence between the Locking settlement boundary and Oaktree Park. The Landscape Officer had no objection to the application in his consultee response and maintained that:

The proposed development of up to 145 houses and associated green infrastructure would be appropriate within this landscape context and it is judged that the effects, as a result of the proposed development, would not give rise to any unacceptable landscape and visual harm.

The result of this proposed designation is restricting a wholly sustainable site, adjacent to the settlement boundary of Locking, from being delivered and significantly boosting the Council’s current dire five year housing land supply position. Gladman’s site was included in Part 1 of CD2a – Schedule of sites to be assessed but was not chosen to be assessed further.

In our Matter 5 Hearing Statement to the SAP Examination (HS-5-5), Gladman contested that there is absolutely no justification whatsoever for the inclusion of this land within the strategic gap; indeed, it appears that it has been submitted at the last minute for inclusion within the strategic gap by the Executive Member for Housing to prevent development from taking place on this site, which incidentally falls within his ward. This is the first opportunity the proposed extension of this strategic gap has been made available for public consultation.

The Council’s own Sustainability Appraisal and evidence base fails to demonstrate that the proposal to include a strategic gap policy in the SAP is justified. It fails to set out the benefits of gap policy and how it is essential to help shape the future settlement pattern so as to allow for the projected growth whilst avoiding loss of settlement identity. It fails to test the effect on the three dimensions of sustainable development with and without strategic gap policy.

Gladman do not consider that it is necessary or justified to include strategic gaps around service and infill villages, as Core Strategy Policies CS32 and CS33 already provide policy protection in this regard. As requested by Inspector Bore at the Remitted Policies Re-examination, flexibility has been built into these policies to allow residential development adjacent to smaller villages, however such sites are subject to criteria which ensure that only sustainable development will be permissible. As such, any development which is likely to cause significant adverse landscape harm, such as the erosion of a perceptual or functional gap between settlements, would not be acceptable in any event as it would not be considered sustainable.

The lack of evidence presented on this matter underlines the fact that the Council’s proposal is inconsistent with national policy which does not provide support for local designations which prevent sustainable development, it is unnecessary and undermines the effectiveness of the plan to deliver sustainable development. It is a policy led by the political desire to prevent development in this area and not, as Strategic Gaps should be, to prevent coalescence of settlements.