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