Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Submitted Sites Submitted sites [View all comments on this section]
Comment ID 1020321//2
Respondent John Phillips Planning Consultancy [View all comments by this respondent]
Response Date 11 Jan 2019


Land at former Blackmoor Farm, Blackmoor, Langford, near Churchill

The land in question measures approximately 3.5 acres (1.4 hectares) and shown on the two accompanying plans (location and site plan) with its boundaries edged red. The site is set close to the heart of Langford with housing development existing on three sides to the north east and south. The land originally formed part of the much larger farm holding known as Blackmoor Farm of which the majority of the farm land to the west of the site was sold to the University of Bristol Veterinary College a number of years ago.

The farm therefore became unviable as an agricultural unit and the site has remained redundant for a number of years. The site still retains a farmhouse close to its entrance which is currently vacant together with a small number of agricultural buildings in a poor state of repair.

The site is relatively flat throughout with current substandard access particularly upon exiting from the driveway given very limited vision to the south along Blackmoor. Any new housing proposal will need to incorporate an entirely new highway access along the site frontage with Blackmoor. Initial discussions with highway consultants have confirmed that a new access can be achieved to meet accepted highway standards.

There appear to be no insurmountable site constraints to future development and we would suggest a possible scheme for between 20– 40 dwellings given current density requirements.

The site is within easy walking distance of the settlement core which is centred around the junction of Blackmoor and Langford Road and relatively close to nearby Langford / Churchill. The site also benefits from the A5 bus service immediately adjacent to the site which links Winscombe / Yatton – Langford – Bristol Airport – and Winford.

We have been instructed by our clients to make the following comments in respect of their land at Blackmoor, Langford near Churchill. Whilst we note that the Issues and Options paper is not intended to be a site specific document and indeed there will be further opportunities during the course of the new local plan process to further promote this land, we believe that the Council should be aware of its future potential for housing at this early stage in the process given the future level of housing provision needed in District as a result of the housing requirement figures stated in the Joint Strategic Plan (JSP) for the four Unitary Authorities which make up the West of England authority.

Strategic context for new housing development in North Somerset

Whilst the JSP has not yet been the subject of an Examination in Public (due to take place in spring / summer 2019), it nevertheless has been through a rigorous public consultation process and is well advanced, and therefore the policies and future distribution of intended housing is well understood. The key components within the JSP and further reiterated in the new local plan is the need for North Somerset Council to provide some 25,000 new homes in the period to 2036. The Council states that it has 13,900 dwellings as existing commitments either in the form of existing permissions or site allocations. This leaves a residual figure of 11,100 dwellings to find throughout the plan period. The vast majority of this residual figure is proposed as part of two large scale proposals at Nailsea/ Backwell (3,175), Banwell (1900) and Churchill (2675). These three proposals result either in new settlements or “bolt- ons” to existing settlements. By their very nature, the scale of proposed development is highly dependant upon huge level of new road infrastructure costs which the Council acknowledge will need to be funded from central government and clearly there is a high degree of uncertainty about such future funding levels. We have also made similar comments previously in other responses to the JSP proposals

In addition to this uncertain future funding, such large- scale proposals will have significant lead in times and that is assuming that planning will be forthcoming in the plan period. Even for relatively minor schemes of say up to 200 dwellings the legal aspects of negotiations both CIL and Section 106 requirements post resolution to grant permission take anything between 12 and 24 months to complete. Indeed, the planning process for such complex developments will be subject to huge public opposition in those areas affected and will inevitably lead to delays in the process of such large- scale applications. All of these factors in isolation and combination will have a significant impact on the length of time that such schemes will come to fruition and we contend given the ongoing new local plan timescale and the discussion that will inevitably take place in the interim including the JSP Examination in Public and subsequent Local Plan Inquiry will result in many such large scale schemes not coming to fruition until the mid - 2020`s at the earliest.

Housing Land Supply Position

As part of its housing land requirement each local authority area throughout England and Wales must demonstrate an ongoing 5- year housing land supply. Any authority which cannot demonstrate the required land supply, is at risk of piecemeal housing development throughout its administrative boundaries as a result of appeal decisions in favour of the housebuilding and development industry. In the case of North Somerset, the latest available information which was recently tested at appeal (June 2018 ref APP/D0121/£/3184845 land at Weston Business Park, Laney`s Drove, Locking, Weston -super-Mare) where the Inspector concluded that the Council could only substantiate a 4.4-year housing land supply based on the evidence provided, and therefore allowed the appeal.

Such development pressures will no doubt continue given this under provision and will lead, if allowed, to un planned development growth in unsustainable locations throughout North Somerset which is clearly contrary to the strategic growth policies contained within the adopted North Somerset Core Strategy and which provides the central core to the New Local Plan.

Given the above two scenarios and the Council`s apparent reluctance to undertake a strategic green belt boundary review in the northern parts of the District we foresee an ongoing under provision of housing land continuing for some considerable time with its consequences described above and we therefore contend that this initial stage in the new local plan process offers the opportunity to consider other suitable opportunities for sustainable development close to existing village settlement boundaries or non- strategic sites.


We therefore support the Councils proposals to improve the opportunity and supply the wide range of housing solutions given the ongoing inability to meet the rolling 5- year housing land supply position.

It is clear however that we have severe reservations about the ability to bring forward the major strategic sites primarily at Nailsea/ Backwell and Churchill / Banwell given the associated level of highway infrastructure required which cannot alone be developer funded and clearly needs central government funding from the outset to have any creditable basis for kick starting new housing developments.

Given the Councils apparent reluctance to undertake a comprehensive Green Belt review as part of an assessment to examine all potentially available sites there will be limited opportunities available to produce the numbers of housing required to meet the plan period to 2036. The Council are making certain assumptions in respect of windfall sites in their calculation but these may well diminish over the years and may not produce the numbers suggested.

We welcome the Council`s review through its Issues and Options paper to look at the wider potential options available to settlements within the rural areas. As stated, we support both Options 2 and 3 of the settlement options hierarchy.

Finally, we wish to flag up our client’s land as a site which has certain credentials in favour of future housing development and which we shall continue to promote throughout the various stages of the ongoing New local Plan 2036 process.

Promotion of land at Blackmoor, Langford, near Churchill.