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 4207073//3
Respondent Deleted User [View all comments by this respondent]
Response Date 18 Dec 2015
Comment

 The local authority proposes the following changes to the policy, however in the absence of a proper assessment of the success or otherwise of existing spatial objectives, eg the jobs-led-housing strategy at WsM, or the alternative spatial options to deliver the higher housing figures, together with an updated SEA, it is not possible to determine whether this policy is sound.

The broad distribution of new dwellings will be a minimum of:

Area                                           Net additional dwellings

                                                       2006–2026

Weston urban area

(excluding Weston Villages)                                         3,458           6,459                            

Weston Villages                               5,500           6,500

Clevedon, Nailsea and Portishead       3,71          4,976

Service villages                                 805           1,861

Other settlements and countryside     522           1,189

Total                                           14,000          20,985"

Therefore this is an objection to proposed policy CS 14.

The proposed increase in overall housing at WsM incl. Weston Villages, that is 4000 homes, needs to be considered on the basis of existing policies for the town, namely the employment led strategy, CS 20. This policies are not remitted and forms a fundamental objective of the overall plan, ensuring that all new housing at WsM contributes to increasing self-containment and does not further exacerbate the existing unsustainable jobs/homes imbalance in the town.

 An additional 4000 homes, if it is not to further exacerbate the imbalance, must by its very nature deliver new jobs. In practice the policy requires 1.5 jobs per new home. This means that a further 6000 jobs, ontop of the 14000 jobs already required to be delivered at WsM, will need to be brought forward sequentially with housing.

Given the current life of this plan, namely 10 years to 2026, this proposed delivery strategy will require 1000 homes per annum to be delivered at WsM for the remainder of the plan period,  on top of the delivery of 1500 jobs per year. The Council have not considered whether or not this is level of jobs is sustainable and deliverable.  If not, then whether or not housing can keep pace with this demand, the jobs - led housing strategy may not be deliverable and therefore the remitted policy may not pass the soundness test.

The first Inspector, who conducted the original Inquiry in 2012, considered the need for review of the plan in 2016 and in 2021 to assess how well the employment led housing was delivering the plan requirements. That position remains within the adopted plan and Policy CS 20.

As part of the consideration of all the remitted policies and in the light of new Policy CS 13, a review should take place in 2016 in to the jobs-led-housing strategy and the evidence brought forward to support and justify the proposed changes to remitted policies.

The remaining distribution of higher housing numbers to Nailsea, Service Villages and other settlements amounts to an increase of 3000 homes to these areas, without any assessment of the impact. These communities already experience substantial out commuting and therefore this increase will only exacerbate the problem. The spatial strategy has been significantly altered in respect of these areas, amounting to a 200% increase housing in these areas.  This is a fundamental change in the plans spatial strategy. This may not represent the most sustainable alternative and certainly needs testing.

Finally, the Council need to consider the text supporting any changes to remitted policy CS 14. They have failed to do this and consequently the existing text does not meet any proposed changes nor the new CS 13.

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