Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Introduction How the housing requirement will be met: [View all comments on this section]
Comment ID 21503969//1
Respondent Richard [View all comments by this respondent]
Response Date 16 Jan 2019

Response to planning consultation

The Housing Crisis is a blight  that no modern democracy will ultimately tolerate.  NSC must understand that  restrictions imposed by the planning system, given the growth of the UK population, have resulted in millions of young people being  unable to afford a home. Many are forced to stay with their parents, others have little alternative other than to live in ruinously expensive rented accommodation much of which is substandard. 

The root cause of the Housing Crisis are highly restrictive planning policies, inflexibly enforced and allied to a vociferous culture of NIMBY ism. The new core strategy is an opportunity for NSC to put in place a planning regime that ensures a supply of new homes in sufficient volume to put an end to the housing crisis in North Somerset.  

On a national basis it is  recognised that only 1% of the land mass of the UK needs to be developed to provide enough houses to solve the housing crisis. This should be relatively straightforward to achieve if planning policies are sensibly revised. I suggest the following;

  1. redraft all planning policies so they are much shorter and practicable.  The current  policies should be replaced by a  single document of no more than 20 pages. Whilst this would be damaging to  vested interests on both sides of the planning fence it would shine a bright light in a place currently inhabited by the suffocating bureaucracy  faced by many small developers. If the planning policies were radically simplified,  it would  make decision making  and investing much easier. This will unshackle small developers, enable many more to enter the market and do what they are good at which is building homes.  This will help far more bricklayers  become house builders.
  2. A gigantic advance would be made if NSC simply enforced the building restrictions noted in the introduction to this policy review. Vis, that all development must be  prohibited within the ANOB, greenbelt and floodplain unless it is on previously developed land or is  required for reasons of national infrastructure.
  3. Outside of the ANOB, greenbelt and flood plain, an assessment should be made of all non developed land to assess its use. This should then be used to inform decisions on which of this land is suitable to be built on. There are thousands of acres of such land in North Somerset that without current planning restrictions, can be sensibly developed.

As a resident of Bleadon I am astonished  that virtually all of the land on the south side of Bleadon Hill has little or no productive agricultural use.  It is not in the ANOB or greenbelt. There are large fields here that have not been grazed or had crops (including grass) harvested for the duration of my residency which is 4 years.  This land is not underused, it is unused! Probably because it is too far away from  local farms to be economically viable.  What should happen to this land?  Within the context of the Housing Crisis and all that this means, what is the purpose of preserving it? This land and land like it should be used to provide homes for our young. 

Planing policies should be adjusted  to enable the  development of land such as this which has acquired protection because of the character assessment ascribed to it even when it is outside of the  ANOB. Preserving land for reasons of its perceived aesthetic attributes when so many people have no where decent to live is perverse.

  1. No further building of dwelling houses should be permitted in the flood plain. It matters not whether the flood plain is classed as A2 or A3 or one of the subdivisions thereof. This is because there is a real danger of a catastrophy occurring in the years ahead.  Arguably the largest natural disaster to impact on the UK during the last 2000 years was the flooding on both sides of the Bristol Channel in 30th January 1607.

A research paper published in 2007 by Risk Management Solutions  (RMS) noted that based on knowledge of maximum possible wave heights, such an event  will probably not repeat for 500 to 1000 years. However, this prediction was based on the science around maximum wave heights. There is clear evidence this is unreliable. The RMS report provides an example which occurred on 27th December 1999 following  “Windstorm Martin” in the Gironde Estuary on southwestern France  at the Blayais nuclear plant. The report notes, 

“…….the storm surge reached one meter higher than had been considered the maximum possible water level at the facility. As a result, the water overtopped the defenses and flooded several meters of the lower level of the facility. Without any internal flood protection system, the water spread over a large network of galleries, damaging pumps and electrical circuits. Although little has been published about what actually transpired through the night of the storm, it is acknowledged that as a result of circuit failures, as well as to the interruption of the external power lines, the four reactors were progressively shut down between 9:00 pm local time on December 27 and 12:30 am local time on December 28. 

On January 5, 2000, the French Nuclear Safety Authority admitted that there had been a Level 2 Emergency at the site. Although not confirmed, there were rumours that three out of the four primary cooling pumps were lost as a result of short circuits during the surge, and that the operators of the reactors had sent messages to the authorities warning of the potential for an impending catastrophe. On the Bristol Channel, the reactors at Hinkley Point and at Oldbury are also vulnerable to being flooded by extreme water levels higher than anticipated in the design of the facilities. Where accompanied by an intense windstorm, the operations and even safety of these facilities could potentially be significantly challenged by the repeat of a surge with tide event comparable to 1607”.

Since the RMS report was drafted far more evidence has come to light concerning the future rise in sea levels arising from global warming. The Envorment Agency report, “Climate change impacts and adaptation” November 2018, included in its summary the following,

 “Unless we take action to reduce greenhouse gas emissions, global temperatures may rise to 4°C above pre-industrial levels by the end of the century. Summer maximum temperatures could rise by up to 10°C in parts of England by the 2080s. Sea levels will rise for decades and centuries ahead. Sea level rise is predicted to be between 0.4 and 1 metre by 2100, and possibly by as much as 4 metres by 2300.”

The impact of such a storm surge induced flood on “flood plain” housing  in North Somerset  would be devastating. NSC should carry out a survey to determine how many homes, businesses and other facilities such as hospitals and care homes will be damaged or destroyed if the 1607 flood was duplicated now or in future when sea levels will be higher. 

To continue to build on the flood plain given the current state of knowledge would be grossly negligent. Granting planning permission in these circumstances risks exposing NSC to potential claims for damages founded in negligence  for loss of life, injury and damage to property.  It is also possible to forsee civil or state sponsored actions for corporate manslaughter.  All of the knowledge concerning these risks is in the public domain. The NPPF demands this is taken into account.

  1. In areas of high housing demand more high rise development should be encouraged. It is self defeating to limit the height of developments to those of high rise buildings in nearby areas. I suggest encouraging several developments of skyscrapers,  close to a railway station/motorway junction, across  North Somerset. This technology has been available for decades. Lets use it. These developments could be made visually interesting and become valuable features of the landscape.   Policies which prevent this sort of innovation as “not in keeping” etc should be consigned to the dustbin of history.
  2. Much more emphasis should be given to creating developments of modern eco style houses built using modern methods such as ICF wall construction with reinforced grass roofs. These dwellings can be errected far more cheaply and quickly than houses built using traditional methods. Small estates of 4 or 5 houses such as these are likely to be of particular interest to small developers and young families. They  blend far more easily into the landscape and are much more resilient to fire and loading from strong winds than more traditional designs. If extreme weather is likely to become a part of our future then so should these houses.
  3. Far more “one off” inspirational houses should be permited in the countryside. A planning officer informed me last year that not one single paragraph 55 house had ever received planning permission in North Somerset. The planning policies which shatter human ingenuity  should be torn up and replaced by policies that make it much easier for such houses to be built.
  4. The policies restricting development based on settlement boundaries and the heirarchy of developable spaces should be dispensed with until the housing crisis is fully resolved.
To address housing crisis redraft and radically simplify all planning policies. Prohibit all development in AONB, Green Belt and floodplain - unless on PDL. Elsewhere assess all non-developed land to assess its use - to inform decisions on land allocations. Flood zones should be protected - danger of 1607 event. Encourage developments of skyscrapers, modern eco style houses, inspirational houses in countryside. Dispense with settlement boundaries.