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 21550017//8
Respondent Lands Improvement [View all comments by this respondent]
Agent Alex Bullock
Response Date 10 Dec 2018
Comment

4. LOCAL HOUSING GROWTH

4.1 We note that, as currently drafted, the Issues and Options document seeks to take forward the figures which are set out within the emerging West of
England Joint Spatial Strategy (JSP). Examination hearings are scheduled for May 2019 and one of the early sessions will be around the overall housing
requirement for the region before moving on to consider some of the identified Strategic Development Locations (SDLs).

4.2 We consider it likely that there will be changes to both for the following reasons:
• the overall housing requirement is too low and does not take full account of the affordable housing need for the region; and
• several of the strategic development locations are not deliverable without significant funding for infrastructure (see our comments within paragraphs 3.21-3.26 above).

4.3 In the case of the housing requirement the current IOP is predicated on the submission version of the JSP which identifies a need for 102,200 new homes across the Plan area and the expectation that North Somerset will deliver some 25,000 homes. Of which only 1,000 dwellings have been allocated to non-strategic growth.

4.4 As we and many others (including the Home Builders Federation) have suggested this overall requirement for the JSP area and that attributed to
North Somerset is too low. This under estimation can be attributed to three inter related issues:
• Addressing housing affordability;
• Low economic growth assumptions; and
• Lack of adjustment to meet significant affordable housing needs.

4.5 Although the JSP is being examined against the requirements of the National Planning Policy Framework (NPPF, 2012), the new standardised methodology for calculation of local housing need based on household projections and housing affordability makes for interesting comparison. It is of note that the  standard method achieves only a minimum housing need figure and further uplifts may be considered necessary.

4.6 The standard method results in the following outcomes:

Authority 1 Year Requirement (dwellings) 20 Year Requirement (dwellings)
Bath & North East Somerset  657 13,138
Bristol 2,440 48,802
North Somerset 1,338 26,760
South Gloucestershire 1,402 28,030
West of England Total 5,836 116,730


Table 1 – West of England Summary Standard Method Requirements

4.7 By consequence if the JSP’s figures are too low and North Somerset’s apportionment then any North Somerset Plan will be seeking to deliver
numbers which are not accurate.

4.8 As a result, it is our opinion that there will be a need to deliver in excess of the 1,000-dwelling non-strategic growth currently identified for North
Somerset over the plan period. We agree that this level of growth should be steered to the most sustainable settlements within the District but acknowledge that the current Issues and Options document does not indicate where the Council intends to meet these needs.

4.9 It is understood that the Council will seek to identify potential sites, using the SHLAA, as part of its preferred option document. Whilst we agree that this
would be a suitable point at which to identify specific sites, we question whether the Council will have an appropriate evidence base to reach such a conclusion given our commentary in relation to the Green Belt as discussed above.

4.10 The conclusions drawn as part of the SHLAA exercise to date focus on the existing policy framework and, as a result, sites within the Green Belt, for
example, are unlikely to score positively. We would therefore suggest that the Council needs to undertake a detailed review of the Green Belt now so that
opportunities are not being lost simply because out of date evidence is informing local plan decision making. We note that a number of the Strategic
Development Locations are currently within the Green Belt but will be removed as part of the future Local Plan adoption process. We would suggest
that a similar approach could also be taken for the non-strategic element.

4.11 A more detailed review of the Green Belt will also help communities producing neighbourhood plans to be able to make allocations to address community needs, particularly those that cannot be met within the existing settlement boundary and are otherwise constrained by the Green Belt designation.

Summary
It is our opinion that there will be a need to deliver in excess of the 1,000-dwelling non-strategic growth currently identified for North Somerset over the plan period. We agree that this level of growth should be steered to the most sustainable settlements within the District but acknowledge that the current Issues and Options document does not indicate where the Council intends to meet these needs.
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