Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Garden Villages and New Communities What is proposed for North Somerset? [View all comments on this section]
Comment ID 21579777//5
Respondent Taylor Wimpey [View all comments by this respondent]
Agent Savills
Response Date 12 Dec 2018
Comment

Additional Response: Garden Villages and New Communities

1.14. The consultation document takes the approach of “rebranding” the Banwell and Churchill SDLs as ‘Banwell Garden Village’ and ‘Mendip Spring Garden Village’.

1.15. However, neither the proposed Banwell or the Churchill SDLs meet even the majority of the criteria for such a description, let alone all of them, as set out in the Ministry of Housing, Communities & Local Government’s (MHCLG) Garden Communities document (August 2018).

1.16. The most obvious failures are in relation to the “locally-led” and “deliverability and viability” criteria. With regard to the former, the Garden Communities criteria emphasises the importance of local engagement and support, however, there is significant local opposition to the proposed Churchill SDL in particular.

1.17. With regard to the latter, as explained in our previous JSP representations (see paragraphs 50 to 78 Appendix 2), these proposed SDLs cannot be considered deliverable due to the complex and fractious patterns of land ownership, the significant infrastructure costs associated with their delivery, insufficient market absorption and inability, based on the WoE authorities’ own evidence, to contribute toward strategic infrastructure and policy compliant levels of affordable housing.

1.18. Continued use of the ‘Garden Village’ branding is misleading and should be removed.

Q10. to Q18. Banwell Garden Village and Mendip Spring (Churchill Garden Village)

1.19. As highlighted above in the introduction to these representations, given the fundamental nature of our
objections to the proposed SDLs at Banwell and Churchill, our response to these questions relates to the
principle not the detail.

1.20. To avoid unnecessary repetition, we have attached (at Appendix 2) our objections to the proposed Banwell and Churchill SDLs, as submitted to the draft JSP. The key elements of these objections are as follows:

 The Banwell and Churchill SDLs are fundamentally inconsistent and incompatible with the draft JSP’s Strategic Priorities and Vision, as well as being unjustified, ineffective and inconsistent with national policy. This internal inconsistency within the draft JSP is the hallmark of unsoundness and both should be removed as SDLs.
 Applying the WoE authorities own Sustainability Assessment Framework criteria to the proposed SDLs at Banwell and Churchill demonstrates that they are not suitable or sustainable locations for strategic scale growth, contrary to national policy and section 39(2) of the 2004 Act and Department for Transport Circular 02/2013.
 SDLs at Banwell and Churchill will not facilitate highways improvements and the development itself cannot afford to pay for necessary infrastructure alone. Nor is there any certainty on any public funding sources. Furthermore, they would perpetuate unsustainable car based travel with no credible or viable mitigation measures.
 Even if development could be delivered in these locations, the economic / job growth evidence clearly demonstrates that there would be insufficient job growth to maintain the long standing objective of enhancing self-containment in Weston-super-Mare.
 New housing at Banwell and Churchill is not needed to meet the future growth needs of Weston-super-Mare as a considerable pipeline of housing land supply already exists.
 Even if allocated, Banwell and Churchill are undeliverable during the JSP plan period due to:

o The complex and fractious pattern of land ownership, with certain landowners expressing a desire not to be involved. Indeed, at Churchill we are aware that NSC have recently halted their attempts to assemble / acquire land that would be necessary.
o The significant infrastructure burden required to enable development which would require considerable public sector funding, represents ‘low value’ for money to the tax payer.
o There is insufficient market absorption these locations to deliver the scale of growth proposed.

o Based on the WoE authorities’ viability evidence, neither proposed SDL would be able to contribute to strategic infrastructure and deliver a policy compliant level of affordable housing.

1.21. These matters cannot be overcome and therefore Banwell and Churchill should be removed from the JSP as SDLs.

1.22. The Vale is the obvious alternative to development at Banwell and Churchill. A detailed justification is set out in Appendix 1, however, this can be summarised as follows:

 The Vale has a long established ‘planning pedigree’ having been independently endorsed as a sustainable location for release from the Green Belt to accommodate residential led mixed use development as part of the South West Regional Spatial Strategy.
 There is a pressing need for strategic development to serve the housing demand emanating from the Bristol urban area and The Vale is ideally located to meet this need.
 The Vale performs very favourably in relation to all the criteria set out in the JSP’s Sustainability Appraisal Framework, and is a demonstrably suitable and sustainable location for development. Therefore, with exceptional circumstances already identified within the JSP plan area, its removal from the Green Belt is justified.
 The Vale is deliverable. Due to a unique set of circumstances, and an outline planning application package in ready-to-submit condition, The Vale can deliver significant residential completions within the first 5 years of allocation.

Summary
The consultation document takes the approach of “rebranding” the Banwell and Churchill SDLs as ‘Banwell Garden Village’ and ‘Mendip Spring Garden Village’. However, neither the proposed Banwell or the Churchill SDLs meet even the majority of the criteria for such a description. The Vale is the obvious alternative to development at Banwell and Churchill.
Attachments