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 Introduction [View all comments on this section]
Comment ID 4207073//1
Respondent Deleted User [View all comments by this respondent]
Response Date 18 Dec 2015
Comment

This representation is made in the light of the proposed changes to remitted policies

CS6 Green Belt, CS14 Distribution of new housing, CS28 Weston-super-Mare, CS30 Weston Villages, CS31 Clevedon, Nailsea and Portishead as a result of the new adopted policy CS13.

These proposed changes amount to a redistribution of higher levels of housing without adequate justification, having regard to consequential effects and the requirement of the local authority, when exercising their plan making functions, to do so with the objective of contributing to the achievement of sustainable development, under section 39(2) of the Planning and Compulsory Purchase Act 2004. Therefore this is an objection in principle to the proposed changes of these remitted policies and a recommendation of what steps the local authority should take in the light of the adopted Policy CS13 and the remainder of the Core Strategy.

If the local authority are prepared to review their strategy with regard to redistribution of housing, then there may be consequential changes Policies CS 19 Strategic Gaps. This representation does not specifically address these changes at this time.

Background

The current Core Strategy has followed a planning process which has been prolonged and less than ideal, given the importance of this plan and its role in planning in the West of England.  The prior history of the development plan has also been less than auspicious, since it has resulted in short term policy making, on condition of early review of the plan, in order to comply with emerging national, regional, or sub-regional policy.  That situation remains in this case, with the newly adopted policy CS13 requiring an early review, to be completed no later than 2018.

Whilst that review may take place alongside the progression of the Joint Strategic Plan, it is noted that that process continues to slip, with earliest expected date of adoption being in 2018.  In practice, the review of this Core Strategy should commence as soon as the West of England SHMA for the wider Bristol area, is agreed by the local authority.  This point has now been reached.

The application of the spatial distribution of housing, which is this basis of these remitted policies, must follow current national guidelines, including NPPF. Whilst there is a need to have regard to existing adopted policies within the Plan, it cannot be the case that where the policy requirement is for atleast a 50 % increase in housing supply, together with a significant backlog, the consideration of such delivery, simply relies upon the same spatial strategy as the earlier, lower housing figure.

The Council must therefore assess any spatial strategy to deliver this higher housing figure both against existing strategic objectives of the plan, whilst undertaking a Strategic Environmental Assessment of that spatial strategy. In the absence of this work, it is not possible to determine the environmental effects of these policy changes, nor to consider their compatibility alongside the adopted plan’s strategic objectives. This process also requires the local authority to consider and assess alternative options, to deliver the new housing requirement Policy CS13.

All of which needs to be considered against a background of up to date evidence, which may impact upon consideration of a spatial distribution strategy, the Strategic Environmental Assessment and ultimately whether the proposed new policies are sound.

Finally, the process of public consultation, which is essential to ensure legal compliance, as well as community/business ‘buy in’ of the remitted policies, needs sufficient information and evidence to allow the community to understand how the local authority reached its conclusions and determined the most appropriate distribution of housing. This information does not form part of this consultation and therefore it is not clear to the public how it was reached. This will need to be addressed.

Conclusion

The local authority’s proposed remitted policies, consequent upon the new Policy CS13, are a significant alteration to the overall spatial distribution strategy of the current plan. Both the scale of housing and its distribution require appropriate testing against SEA, new evidence on the HMA, as well as the existing policies of the plan.

The existing plan has a scheduled review in 2016 , to consider the success of the jobs-led homes strategy at WsM. This evidence needs to be brought forward, so the local authority and the public can assess the deliverability of the proposed spatial distribution strategy.

The local authority’s absence of considering alternative options, including Green Belt, suggests that it is applying its own policy constraints to this process, without considering all the options within an objective process.

Finally, the emergence of the SHMA for the West of England is a material factor, that helps to better understand the function of the HMA, at a time when the local authority are trying to address themselves towards the spatial distribution strategy and appropriate policies to achieve it. Whilst the overall housing requirement is now fixed until 2018, through new Policy CS13, the spatial distribution strategy must take account of the most up-to-date evidence, including the wider SHMA. To fail to do that, could direct the local authority on a spatial distribution path of increasingly unsustainable development, unable to meet the needs of the wider HMA.  The consequences for the backlog and the jobs-led-homes strategy at WsM, means that the spatial distribution strategy needs to have considerable flexibility within it, to meet this increasing demand. Simply sticking to the same strategy as resulted from the previous plan would be a mistake that would take many years to correct.

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