Site Allocations Plan March 2016

Document Section Site Allocations Plan March 2016 PUT FORWARD A SITE OR MAKE GENERAL COMMENTS Put forward a site [View all comments on this section]
Comment ID 11844417//1
Respondent Tetlow King (admin) [View all comments by this respondent]
Response Date 04 May 2016
Comment

On behalf of our client, who owns a 3.2 hectare parcel of land North of Lyefield Road, Worle, Weston-super-Mare, Tetlow King Planning is instructed to make a representation on the North Somerset Site Allocations Plan: Consultation Draft. We have submitted previous representations demonstrating the sustainable credentials of our client’s site in relation to the January 2015 Call for Sites consultation which sought to form an evidence base for the Housing and Economic Land Availability Assessment; the consultation on the North Somerset Core Strategy remitted policies in December 2015; and the consultation on the West of England Joint Spatial Plan: Issues and Options document. It is considered that our Client’s site is suitable for residential development; this is corroborated by its scoring in the Council’s Sustainability Appraisal Site Assessments document in which it scores equal to or higher than ten of the sites which are proposed to be allocated within the Draft Site Allocations Plan. This representation seeks to comment on the soundness of the Draft Site Allocations Plan, with reference to our Client’s site situated to the North of Lyefield Road, Worle. The representation demonstrates that the failure to allocate our client’s site is unjustified and in order for the Site Allocation Plan to be found sound, our client’s site should be allocated now. A copy of the site location plan is attached.

As you will be aware, the Council should only submit a plan for examination which it considers is “sound”. The National Planning Policy Framework (NPPF) sets out a number of tests which a plan must meet in order for it to be found as sound, these are listed below and discussed in further detail throughout this representation.
Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.


Flood Risk - Applying the Sequential Test in the preparation of a Local Plan
The Planning Practice Guidance (PPG) (Paragraph 020, Reference ID 7-020-20140306) sets out that in the preparation of Local Plans “the Sequential Test should be applied to the whole local planning authority area to increase the possibilities of accommodating development which is not exposed to flood risk”.

This builds on earlier guidance on the application of the NPPF set out in the PPG where it is stated that “in plan-making, local planning authorities apply a sequential approach to site selection so that development is, as far as reasonably possible, located where the risk of flooding (from all sources) is lowest, taking account of climate change and the vulnerability of future uses to flood risk” (Paragraph 001, Reference ID 7-001-20140306).

It is concerning therefore, that a large number of the sites which the Council propose to allocate, which currently do not benefit from any form of extant planning consent for residential development, are located within Flood Zones 2 and 3.
In the Sustainability Appraisal it is noted that for the proposed allocation of 73 dwellings at Bridge Farm, Weston-Super-Mare, the “Flood Zone has been reassessed and site is in Flood Zone 3 – sequential and exception test required”. For the proposed allocation of 47 dwellings at the former Bournville School site, Selworthy Road, Weston-Super-Mare, the following is noted; “Flood Zone 3A -Sequential and Exception test required”.

Based on the Council’s analysis set out in the Sustainability Appraisal Site Assessments, our client’s site (shown on the enclosed Site Location Plan) is demonstrated to be as sustainable, if not more sustainable, than ten of the sites proposed to be allocated in the draft plan. Crucially, the site is outside of Flood Zones 2 and 3. It is therefore considered that the Draft Site Allocations Plan fails to apply a sequential approach to site selection as required by national policy by choosing to allocate sites in Flood Zones 2 and 3 over our client’s site.
In its current form, the Draft Site Allocations Plan therefore fails the tests of soundness by virtue of the fact that it is not justified, as it does not represent the “most appropriate strategy, when considered against the reasonable alternatives” and it is not consistent with national policy by virtue of the fact that it does not “enable the delivery of sustainable development” in accordance with policies on flood risk in the NPPF.

Windfall Sites
It has been highlighted by the examining Inspector of the Core Strategy that there are concerns that the housing figure settled upon of 20,985 to be provided over the plan period could be found to be needed to be higher, as such the figure is to be the “minimum” to be provided over the period of the plan with the Inspector noting that “framing the housing requirement as a minimum figure enables additional amounts of housing to be delivered” (Paragraph 63, Inspector’s Report on Policy CS13, March 2015).

It is disappointing therefore that the Council has allocated 1,200 homes to windfall sites over the plan period. Windfall development is unpredictable by its very nature, it would be far more beneficial and provides far more certainty that the Council will be able to achieve the proposed housing numbers, if sufficient and sustainable sites, which are also deliverable by virtue of them being devoid of any technical constraints, are allocated, this will ensure that the Council will not be challenged on its land supply in the future when assessments are made of the ability for them to meet the minimum housing figure needed per annum in light of any delays or issues which arise on allocated sites.

The Draft Site Allocations Plan therefore does not pass the tests of soundness in relation to being “positively prepared”.

Housing Distribution and Sustainable Development
The North Somerset Core Strategy spatial strategy seeks to focus the majority of new development at Weston-super-Mare, followed by the towns of Clevedon, Nailsea and Portishead and then the nine service villages. This approach seeks to ensure that new residential development is brought forward in the most sustainable locations in the region and in turn, seeks to ensure accordance with the presumption in favour of sustainable development which should be seen as “a golden thread running through both plan-making and decision-taking” as set out in the NPPF.

The Draft Site Allocations Plan proposes a number of allocations at villages and in the countryside totalling 243 dwellings. This quantum of dwellings does not accord with the strategy set out within the North Somerset Core Strategy and as can be seen from the sustainability appraisal site assessments, these sites score very poorly in terms of their sustainability.
We also note that of these 243 dwellings, 124 are proposed at Redwood Lodge, Failand. The comments supplied by the Council for this allocation, despite it scoring very poorly, state that there “may be some potential for conversion / redevelopment as a Care Village given its remote location”.

This view that care development is appropriate in remote locations is not consistent with the North Somerset Core Strategy Policy CS26: Supporting healthy living and the provision of health care facilities which requires “joint working with health providers to help deliver a district-wide network of health facilities which are located within towns or service villages and are easily accessible by sustainable modes of transport or travel” (emphasis added).

It is also not consistent with the policies of the NPPF which highlights the link between health and planning and seeks to promote healthy communities. Further guidance on health within planning and the interpretation of the NPPF is given in the PPG which sets out the following:

“The link between planning and health has been long established. The built and natural environments are major determinants of health and wellbeing. The importance of this role is highlighted in the promoting health communities section. This is further supported by the three dimensions to sustainable development (see National Planning Policy Framework paragraph 7).

Further links to planning and health are found throughout the whole of the National Planning Policy Framework. Key areas include the core planning principles (see National Planning Policy Framework paragraph 17) and the policies on transport (see National Planning Policy Framework chapter 4), high quality homes (see National Planning Policy Framework chapter 6), good design (see National Planning Policy Framework chapter 7), climate change (see National Planning Policy Framework chapter 10) and the natural environment (see National Planning Policy Framework chapter 11).” (Paragraph 002, Reference ID 53-002-20140306).

In light of the distribution strategy set out in the North Somerset Core Strategy and the presumption in favour of sustainable development set out in the NPPF, it is therefore considered that the allocations at sites in the countryside and in villages not recognised as service villages is inappropriate and also fail the tests of soundness by virtue of the fact that there allocation is not consistent with national policy or justified.

It is also considered that the allocation of a large number of dwellings in the service villages is disproportionate. Whilst all of there are nine settlements listed as service villages within the North Somerset Core Strategy, these settlements vary considerably in terms of their size and their sustainability in terms of such things as the services available within them and the transport connections to them.

For example, the sites in Churchill score very poorly in the Sustainability Appraisal Site Assessments; 219 dwellings are proposed through allocations for Churchill which equates to a 24.6% increase in the number of dwellings within the Churchill Parish which as of 2011, consisted of a total of 889 dwellings (Office for National Statistics). Considering the lack of services, facilities and transport links within Churchill, this increase is disproportionate and is not sustainable; this is fully reflected in the poor scores shown for the Churchill allocations in the Sustainability Appraisal Site Assessments. The drafting of the Site Allocations Plan with the proposed level of housing at smaller, less sustainable settlements such as Churchill does not accord with the tests of soundness set out above due to the fact that it fails to accord with national policy on sustainable development. It also does not accord with the North Somerset Core Strategy distribution of housing strategy.

A higher proportion of the housing allocated at such settlements as Churchill, should be allocated at the main settlements in the region by virtue of their sustainable credentials. Weston-super-Mare is the largest and most sustainable settlement in the region. The failure to allocate our client’s suitable, sustainable and deliverable site on the edge of the settlement, outside of the Flood Zones and close to local transport, schools and employment is unjustified and we request that the deliverable site should be allocated now.

Attachments