Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document North Somerset Issues Q2. Do you agree with these or are there other challenges or issues which we have not included and how might the Local Plan address these? [View all comments on this section]
Comment ID 21472033//1
Respondent Dave Akam - David Lock Associates [View all comments by this respondent]
Response Date 10 Dec 2018
Comment

David Lock Associates has prepared this statement on behalf of Hallam Land Management Ltd (HLM), who are promoting strategic-scale, mixed-use development on the Land East of Clevedon (Junction 20); for which they have a long-term agreement in place with landowners. HLM are the land promotion arm of Henry Boot PLC who have a proven track record in bringing forward new strategic development opportunities, taking responsibility for ensuring the delivery of sites including the provision of related infrastructure, including affordable housing.


We have made representations to the West of England Joint Spatial Plan, related specifically to the 12 broad areas for development referred to as SDLs, but also generally in relation to the housing requirement which HLM consider falls short of meeting housing need. The Land East of Clevedon is currently identified as a contingency site within (WoE JSP) submission document. The relevant policy is Draft Policy 2 which identifies an additional contingency supply of around 3,000 dwellings, across the West of England Authorities, should development not come forward as anticipated. Land East of Clevedon is identified as the contingency site for North Somerset, and therefore is of significance to the Issues and Options consultation to this Local NSC Local Plan review.


To summarise, HLM have submitted representations to WoE JSP that questions the effectiveness of the adoption of a contingency category which is only 3% of the total supply figure and proposes that the Authorities should proceed with the contingency figures as part of the total supply, so that these numbers are capable of contributing in the round to the overall housing demand.


HLM have prepared and submitted an evidence base that provides confidence underpinning the identification of the Land East of Clevedon as an SDL for North Somerset in its own right in the JSP – with a capacity to deliver some 2,500 homes, employment land and local retail facilities and services. Importantly, the site performs a key role in the wider development strategy that is required to unlock the SDLs at Nailsea-Backwell in the short-term which could alleviate reliance on costly transport schemes for which external funding might have to be secured through the provision of a new link road to Junction 20.


The principle and scope of the contingency sites will be a key focus for the upcoming WoE JSP examination, which could result in significant amendments to strategic outcomes for the Plan, and therefore a good degree of flexibility is needed at this Issues and Options stage to ensure that the NSC Plan review can progress alongside and in accordance with an as yet untested wider WoE strategy.


In the event that the contingency category is retained in the JSP, its evidence base makes clear that the contingency sites will come forward through Local Plan review, and therefore it is critical that the North Somerset Council Local Plan 2036 provides an appropriate policy framework to support the delivery of this site, whether it is to reflect its amended “outright” SDL status in the JSP as HLM propose, or if retained as a contingency site. HLM consider that the Issues and Options document as currently drafted does not secure this effectively. The site should be assessed now, at the same time as the other SDLs, rather than upon early review of the plan.

In addition, and notwithstanding the compelling residential-led mixed use credentials of the site, HLM consider that this site also has the potential to meet employment needs of North Somerset in the short-term.

HLM broadly agree with the scope of issues and challenges outlined in the consultation document, and have the following comments relating to specific key issues.


HLM note that there is no reference to meeting local housing needs to include affordable housing at Clevedon. It is widely recognised that North Somerset has housing affordability issues, with house prices exceeding affordability. It is therefore considered necessary to ensure due consideration is given to meeting affordable housing needs as part of a balanced delivery of homes within the Clevedon area.


Issue 1 - How to help promote and increase the attractiveness of the town centre to both users and investors such as retailers/other businesses.


Providing a sufficient mix of constant housing supply is a key factor in supporting existing services and create new demand for service sector businesses as well as a wider range of employment sectors. Indeed NPPF Paragraph 8 recognises that such economic and social objectives are intrinsically interlinked in the pursuit of sustainable development and joined-up planning. Clevedon has experienced limited residential development over the past plan period, and as a result its town centre has not experienced the increase in footfall that other towns across the district have, which has likely limited the opportunities for the growth of town centre.


The current settlement hierarchy places Clevedon at the second tier; below Weston-super-Mare but equal to Portishead and Nailsea. However, recent development across the district has not come forward in accordance with this hierarchy – Weston, Portishead and Nailsea - have all benefitted from more development in recent years. NSC should now be seeking to address this unbalance and take this opportunity to secure housing allocations in Clevedon, which is considered to be a more effective strategy than the approach which relies on the emerging ‘Urban Living’ initiative which, whilst may achieve indirect benefits, is not prescriptive or strategic enough to direct sufficient development to a Tier 2 settlement.


There is also a significant opportunity for Clevedon to increase town-centre and sea-front footfall perhaps as part of a wider tourism strategy which would have strong support through proposed enhanced infrastructure connections to encourage local tourism from Nailsea, Backwell (strategic growth locations), and Bristol (the enhanced infrastructure in this case being the link between Nailsea and Backwell, which the land to the East of Clevedon will help to facilitate).
Issue 4 - How to encourage the retention of business/employment uses within the town and to the south at Clevedon 5/20 and west of Kenn Road to ensure there are opportunities to work locally, rather than commuting.


Land West of Kenn Road has been allocated for a considerable time within the current Core Strategy, but with no viable employment schemes coming forward. This may be in-part due to its poor accessibility (relative to other areas of the town and around Junction 20), particularly with regard to the strategic highway network, but also to the town centre and local bus routes. The absence of a good mix of available and accessible employment land has wide-ranging disadvantageous implications from economic, sustainable, and local employment perspectives. Additional land should be allocated – particularly sites well located to the primary road network.

With a shift in retail habits, and consumers now purchasing more of their goods online, there is a growing requirement for larger distribution units (such as those which have been constructed at Avonmouth) in locations with excellent connectivity.
The Land East of Clevedon presents an opportunity to allocate new, high-quality employment land adjacent to Junction 20 that could support a range of employment uses that offer flexibility in terms of potential uses and scales, and high accessibility; not only locally within and around Clevedon but also within the wider district supported by proximate access to the strategic highway network. New employment land opportunities would also be supported by a committed infrastructure investment in the Nailsea to Clevedon corridor as well as improvements to the M5, and its delivery could be further supported by HLM, an experienced developer with a proven track record in strategic delivery.


Issue 5 – Is there a need to review accessibility by car and public transport to the motorway network and Bristol?
HLM believe there is evidenced need to review strategic connectivity from Clevedon eastwards towards the SDLs at

Nailsea and Backwell, and onwards to Bristol. Not only is the provision of enhanced (in the form of frequency and efficiency) transport important to support the objectives identified in issues 1 and 4 above, but in fact it would be practical and effective for NSC (and WoE) to align infrastructure enhancements with strategic housing and employment allocations along a Clevedon – Nailsea/Backwell – Bristol growth corridor to achieve greater economies of scale and wider sustainability benefits. The WoE JSP evidence base, namely Transport Topic Paper 8, presents a number of infrastructure project packages relating to Nailsea and Backwell. HLM supports in particular those measures identified in Package 3, which includes a new highway link between B3130 (Tickenham Road) and M5 Junction 20. This link is reflected in the masterplanning for the Land East of Clevedon (see concept diagram HLM045/021). Furthermore, the Emerging Findings Transport Report shows the long-term potential of a Nailsea to Clevedon link road, which has also been future-proofed in the masterplanning again shown on the concept plan providing in support of these representations. It is clear that allocation of the Land East of Clevedon would help to secure confidence in the delivery of the chosen transport scheme to facilitate better connections between Bristol and Clevedon.


Issue 6- If the proposed contingency housing site identified in the JSP to the east of the M5 J20 is ever brought forward in a future review of the plan, how could this be successfully integrated into the town


A ‘Proposed Concept Diagram’ (ref HLM045/021) is enclosed which reflects those drawn for the SDLs within the consultation document. The concept seeks to demonstrate how land east of Junction 20 can deliver a sustainable community that is physically and functionally part of Clevedon, and accommodates aspirations to improve strategic connectivity between Clevedon, Nailsea and Bristol. The concept and Vision is for a mixed-use settlement which is inherently sustainable with strong connections to Clevedon and the wider area, with particular focus on establishing good pedestrian, cycle and public transport links to Clevedon and supporting sustainable transport choices. Court, Manmoor, and Davis Lanes are to be retained and enhanced, whilst a new junction to Tickenham Road and new spur off M5 Junction 20 are proposed which will greatly enhance multi-modal connectivity of the site to Clevedon and indeed eastwards to Nailsea and beyond. Public Right of Way LA22/15/70 and the Avon Cycleway (National Cycle Route 510) run through the site and can be capitalised on to provide active travel to Clevedon. A number of facilities within Clevedon are within reasonable walking distance, including schools, employment areas, supermarkets and health facilities, though strategic development of the proposed scale will support new local facilities.

In addition, depending on scale / mix, the site has the capacity to enhance Clevedon’s existing facilities by the provision of additional ‘Town Benefits’ such as community, sports, and education provision. Whilst physically the site is beyond the M5, connectivity enhancements and potential shared facilities will enable a sustainable, long term, future direction of growth to Clevedon.

Summary
The housing provision proposed in the JSP falls short of meeting housing need.

HLM question the effectiveness of the adoption of a contingency category which is only 3% of the total supply figure and proposes that the Authorities should proceed with the contingency figures as part of the total supply, so that these numbers are capable of contributing in the round to the overall housing demand.

An SDL to the east of Clevedon performs a key role in the wider development strategy.
Attachments