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 Housing Land Supply [View all comments on this section]
Comment ID 930433//2
Respondent Deleted User [View all comments by this respondent]
Response Date 17 Dec 2015

Housing Land Supply


2.7       The table in para 16 purports to show the current housing land supply position. Again this is             not supported by evidence and detailed assessments particularly as to the assessment of the        shortfall figure of 1715 dwellings so derived. Employment led development within the Weston area and the capacity of the housing market to provide the high level of housing   completions envisaged out of a very concentrated area need to be assessed properly.

2.8       It has also become apparent in recent months that the issue of the provision of affordable    housing may well continue to impact on the viability of housing schemes following the     Autumn Budget measures, which in turn threatens to further delay the commencement and/or       progression of the large but few allocations in the Weston area. The adjoining authority of          South Gloucestershire has most recently acknowledged such problems with its large scale    allocations.

2.9       Para 17 states that, based on the Council’s figures, 13,559 dwellings need to be delivered over         the remaining 11 years of the plan period. The majority of these are proposed in the Weston      area including the additional 4001 dwellings proposed under policies CS14 and CS28. It is        contended that to simply add these numbers on without reviewing the ability or otherwise to        provide capacity for further housing development under the other remitted policies is to fail to    adequately assess the consequences and implications of the near 50% increase in the housing    target under CS13.

            Can the Revised Housing Target of 20,985 dwellings be delivered without changes to the     other remitted policies?


2.10     Paras 22 – 24 contains a number of statements worth considering. Flexibility is suggested to            be inherent in the CS, allegedly demonstrated by the illustration of the draft 2013 S&P making provision for about 18000 dwellings when only 14000 were then the subject of Policy     CS13. We believe this 18000 figure was contained in the then SHLAA which predated the       HELAA but in itself this figure has not been proven as deliverable in accordance with            relevant policies at that time. Part 2 when it proceeds will start to address such issues.

2.11     Para 24 is correct but there is a “chicken and egg” scenario involved in that NSC considers   the policies should be the starting point in the process and therefore, as pronounced in para         25, no change is required to the remitted policies. Notwithstanding the intimation that the shortfall is relatively small, these are real dwellings that are required on an annual basis to             meet demand. Therefore the remitted policies must address whether that will happen by     analysis and evidence and thereafter should be changed if required.

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