Sites and Policies Plan Consultation Draft

Document Section Sites and Policies Plan Consultation Draft Clevedon, Nailsea and Portishead NA3 [View all comments on this section]
Comment ID 8130849//2
Respondent Deleted User [View all comments by this respondent]
Agent Deleted User
Response Date 18 Apr 2013
Current Status Accepted
Comment

 

Policy NA3 Trendlewood Way, Nailsea

 

3.1 Policy NA3 is concerned with land at Trendlewood Way Nailsea. This area of land

has historically been allocated for community uses but has failed to ever come

forward as such.

3.2 The Sites and Policies DPD, proposes to re-allocate the site for a mix of uses, still

including a significant proportion of community uses.

3.3 Led by the aspirations of Nailsea Town Council, Policy NA3 proposes the following

uses for the land:

At least 0.7 ha for community uses, to include 0.5ha allotments and 0.2 ha for

another community use such as a church and car park;

Retention and management of the woodland adjoining the site to the north west;

Provision of retirement homes on the remainder of the site (approximately 14

dwellings; and

Protection of living conditions of existing residents and future occupants.

3.4 No evidence of the need for such uses or the suitability and viability of this particular

site for them is put forward by the Council. In this way the policy cannot be

considered deliverable and therefore is ineffective.

3.5 The fact that the site has been allocated for community facilities for over a decade

and never come forward as such indicates that there is no demand for such

development within this area of Nailsea. The proposed allocation by the Sites and

Policies DPD will only continue this position and the site will continue to make no

positive contribution to the community of Nailsea.

3.6 The provision of 14 retirement dwellings will not provide enough return to enable the

landowner and developer to deliver the proposed level of on-site community facilities.

The proposed allocation is therefore contrary to paragraph 173 of the NPPF which

states that:

The sites and scale of development identified in the plan should not be subject to

such a scale of obligations and policy burdens that their ability to be developed viably

is threatened. To ensure viability, the costs of any requirements likely to be applied to

development ...should when taking account of the normal cost of development and

mitigation, provide competitive returns to a willing land owner and willing developer to

enable the development to be deliverable

3.7 Furthermore, the types of community uses proposed are also considered

inappropriate in this location.

Church

3.8 There is no evidence of demand for a new church within Nailsea. For example,

neither the Parish Plan undertaken in 2008 nor the Parish Plan or Policy Statements

identify the need for a new church.

3.9 The 2011 Census shows an increase in the number of Nailsea residents who state

that they have no religion from 16% in 2001 to 27% in 2011. At the same time the

number of residents who state their religion as Christianity has declined by 13%.

3.10 There are already seven churches in Nailsea including St Francis Church which is

located within walking distance of land at Trendlewood Way.

3.11 Furthermore, there is no evidence of funding to buy the land and deliver such

development, nor a willing operator.

Based on all of the above, the proposal within Policy NA3 for a church and car park is

not justified and not effective. The policy cannot therefore be considered ‘sound’.

Allotments

3.13 As confirmed by proposed Policy DM 56 which permits new development associated

with local food production in the countryside, allotments are considered acceptable

development outside of the settlement boundary.

3.14 Land at Trendlewood Way is a site within the existing settlement boundary which

provides a unique opportunity to deliver truly sustainable housing in line with the

objectives of the adopted Core Strategy and within the next 5 years. Development of

the site for housing with a financial contribution to the provision of off-site allotments

would therefore represent a more appropriate form of development in this location.

3.15 Given the apparent importance of Allotments to the Town Council it is unjustified that

no allotments are sought on the large mixed use allocation at land north west of

Nailsea. This scheme will generate a significant number of new dwellings and

therefore create increased demand for allotments.

Retirement Housing

3.16 The restriction of the development to only retirement housing is also unjustified and

does not make the most effective use of the land.

3.17 Land at Trendlewood Way is within walking distance of both Nailsea Secondary

School and St Francis Primary School. It therefore provides a highly sustainable

location for the provision of family housing (as desired by the Town Council to

prevent school closures).

3.18 Furthermore, proposed Development Management Policy 40 which relates

specifically to the provision of retirement accommodation states that ‘shops, public

transport, community services and medical services’ should be easily accessible by

residents with limited mobility and no access to a car. On the basis of this policy, land

at Trendlewood Way is not therefore the most appropriate location for retirement

accommodation.

3.19 All community services and medical services which would be required by elderly

people are located along the High Street of Nailsea around 1 mile from land at

Trendlewood Way – this exceeds walking distance for people with limited mobility.

3.20 The proposed development of 450 dwellings at North West Nailsea will by virtue of

proposed Development Management Policy 40 (it exceeds 100 dwellings) will be

required to provide a proportion of retirement accommodation and it is considered

that this location is far more appropriate in terms of distance form community and

medical services for such accommodation.

4. CONCLUSION

4.1 As demonstrated by the information provided above, in their current state, Policies

NA2 and NA3 of the Consultation Draft Sites and Policies DPD are unsound.

4.2 Policy NA2 proposes to allocate a large mixed-use development on an area of land

without any evidence that:

The level of housing proposed is justified. The Core Strategy identified a target of

210 dwellings for Nailsea and potential for mixed use development adjacent to

the settlement boundary where it would meet identified local needs. No work has

been undertaken to quantify local housing needs in Nailsea, therefore the

proposed level of development at North-West Nailsea cannot demonstrate that it

meets this criteria.

 

This site is the most appropriate. No supporting technical evidence is provided to

demonstrate that the entire settlement boundary of Nailsea has been evaluated

and that this location represents the most sustainable location for an alteration. It

is not therefore demonstrated that land to the north-west of Nailsea is the most

appropriate strategy when considered against reasonable alternatives.

 

Land to the north-west can actually be delivered within the plan period. This is

particularly pertinent given the sites history. Despite allocation in a previous plan

and a planning application the site has not come forward and is known to suffer

from a number of constraints. The policy is not therefore shown to be deliverable

over the plan period and is not therefore effective.

4.3 Policy NA3 proposes to allocate land at Trendlewood Way for a mix of community

facilities and retirement housing without any evidence of:

Demand for any community facilities within this area. The site has been allocated

for community uses for over a decade. It is clear that there is no identified

demand for a specific community facility as the policy broadly refers to

“community uses such as a church and car parking”. There is certainly no

evidence of demand for a new church in Nailsea, particularly in this area. The

policy is therefore unviable, unjustified and ineffective.

The need to locate allotments in this particular location. Whilst it is accepted that

it would be desirable to provide additional allotments in Nailsea, there is no

justification for them in this location. Policy DM56 of the same document allows

allotments outside of the settlement boundary, therefore a number of other

suitable locations exist for the provision of allotments. Land at Trendlewood Way

is one of the only suitable sites for residential development within the settlement

boundary and within the next five years. Such development is required to fund

the delivery of allotments in Nailsea.

The suitability of this location for retirement homes. Land at Trendlewood Way is

not located within walking distance of the town centre for people with mobility

problems. In line with Policy DM40 of the same document it would not therefore

represent an appropriate location for older peoples housing.

4.4 Land at Trendlewood Way is one of only three sites within the settlement boundary

which were identified by the Council’s SHLAA as having potential for the delivery of

market housing within the next five years.

4.5 In light of the Council’s acceptance of a need for more family housing in Nailsea and

the current lack of a housing target and therefore five year supply across North

Somerset, land at Trendlewood Way is an opportunity to help address these two

issues. The proposed allocation of the land for retirement homes, allotments and an

unidentified community use is not justified and is an ineffective use of a highly

sustainable piece of land within the settlement boundary and within walking distance

of local schools.

4.6 There is no demand for a community use in this area and no offers from operators of

such uses to buy the land and fund development of such. The same is true of

allotments.

4.7 The proximity of the site from the town centre makes it an inappropriate location for

retirement housing. Retirement housing, community facilities and allotments will in

any case need to be provided by any large scale mixed use allocation adjacent to the

settlement boundary.

4.8 As proposed, Policy NA3 will only prevent land at Trendlewood Way from coming

forward and making a positive contribution to the local community.

4.9 Allocating land at Trendlewood Way for 100% open market housing is therefore a

more appropriate and effective use of this land. Such an allocation would still deliver

off-site financial contributions to community uses and allotments as appropriate.

 

 

 

 

 

 

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