North Somerset Core Strategy Consultation on consequential changes to remitted policies CS6, CS14, CS19, CS28, CS30, CS31, CS32, CS33

Document Section North Somerset Core Strategy Consultation on consequential changes to remitted policies CS6, CS14, CS19, CS28, CS30, CS31, CS32, CS33 Policy CS14 Distribution of new housing [View all comments on this section]
Comment ID 14343521//1
Respondent Deleted User [View all comments by this respondent]
Agent Deleted User
Response Date 18 Dec 2015
Comment

This representation is written in response to North Somerset’s consultation on consequential changes to remitted Core Strategy policies, on behalf of our client who control a 3.2 hectare parcel of land North of Lyefield Road, Worle, Weston-Super-Mare, which they consider is suitable for development. Previous representations have been made to the Council’s SHLAA. A location plan is attached.

Site Suitability

The site is directly adjacent to the development boundary and is well located to the centres of Worle and Weston-Super-Mare. The site is suitable for integration within the development boundary now to take account of the increased requirement to more dwellings. The site comprises of typical agricultural fields with boundary hedges. A number of agricultural buildings are currently on site but none are of traditional appearance or harbour any significant architectural merit.  There are also two residential dwellings adjacent to Lyefield Road.  Crucially for the area, this site is not within Flood Zone 2 or 3 on the Environment Agency flood maps and therefore falls within Flood Zone 1, the lowest flood zone within which development is deemed to be acceptable from a flood risk perspective. Highways advice has been obtained and it is considered that suitable access can be achieved from Lyefield Road. The site has no other designations. The site is well serviced and is available now.

Our principal concerns are not only to optimise the provision of housing but also to ensure the preparation of consistent planning policy documents which are based on robust and credible evidence. This is to ensure not only that the correct housing target is achieved, but also that the plan guides future housing to the most sustainable locations and those most in need. Weston-Super-Mare is the principal town and the majority of the Districts growth (and the additional requirements arising) should be directed towards the Town.

Remitted Housing Policies

The housing requirement confirmed by the Secretary of State is 20,985 dwellings over the plan period from 2006 to 2026.  This is an extra 1,715 on top of the 19,270 dwellings that the Council believe they can demonstrate will come forward through their land supply calculations.

Policy CS14, Distribution of New Housing, amends the housing figures to be distributed across the district as follows:

  • +3,000 dwellings in Weston urban area;
  • +1,200 dwellings in Clevedon, Nailsea & Portistead;
  • +1,000 dwellings in Weston villages;
  • +1,000 dwellings in service villages; and
  • +600 dwellings in other settlements.

The Council have stated that the 1,715 shortfall is a small enough number to be dealt with via the upcoming Site Allocations Part 2 Plan, it is our belief however that this shortfall should be added to the above figures and distributed amongst the above identified areas set out under policy CS14, with Weston-Super-Mare receiving proportionally more than other settlements due to its higher order settlement status. This will give greater clarity to the location of suitable sites for the forthcoming Site Allocations Part 2 Plan based on identified need. It will also enable sites not identified in the immediate term being considered against a revised housing target in an adopted Core Strategy. It is not acceptable for a “part 2” plan to be left to languish if for instance the political will does not seek to progress the second part of the plan.  In such circumstances that there is a delay in the site allocations plan and the housing overall housing completions do not progress there is clearly a need to provide additional land, such as the land at Lyefield Road. If there is no part 2 plan then the Core Strategy could be considered out-of-date as part of the plan is absent (Paragraph 14 NPPF).

Based on the evidence of need which shows that a higher proportion of housing should be directed to Weston urban area, it follows that a large proportion of the 1,715 shortfall should be directed to the Weston urban area.

The above comments are intended to be constructive, to ensure the policies are found sound at examination. We would like to be consulted on further stages by email only to consultation@tetlow-king.co.uk.

Do you consider it necessary to participate at the oral part of the examination? No
Attachments