Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Local Housing Growth Where will the non-strategic sites be? [View all comments on this section]
Comment ID 14590529//1
Respondent Persimmon Homes Severn Valley [View all comments by this respondent]
Response Date 10 Dec 2018
Comment

North Somerset Wide Issues

The map on page 8 of the document maps the 3 main constraints in North Somerset – Green Belt, AONB and flood risk area. However, these are then treated as absolute constraints and the main areas of proposed development are located in those areas where none of these constraints exist.  In the first instance this is an issue that will be explored at the Joint Spatial Plan (JSP) examination, but even if that does not make any changes which would affect the Local Plan Strategy, or if the JSP requires more development to be found, it is also relevant for the Local Plan 2036.  NPPF paragraph 7 says ‘the purpose of the planning system is to contribute to the achievement of sustainable development’.  Therefore the JSP and the Local Plan have to demonstrate that the proposed development locations meet that high level objective.  Constraints should not be considered as absolute if they preclude the consideration of more sustainable options.  The JSP dismisses all alternatives without assessing them in the same level of detail as the JSP proposals themselves. 

Even if the JSP remains unchanged, the Local Plan will need to demonstrate the development it proposes is sustainable and carry out the same assessment on detailed rather than strategic proposals. In that respect it should consider the potential for sustainable locations in the Green Belt and it should not assume the flood risk areas on the constraints map are absolute constraints as demonstrated by existing development in flood risk areas which are otherwise protected.

Summary
The Council have treated Green Belt, AONB and flood risk as absolute constraints. The Local Plan should consider the potential for sustainable locations in the Green Belt and it should not assume the flood risk areas on the constraints map are absolute constraints as demonstrated by existing development in flood risk areas which are otherwise protected.
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