Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation 1. General comments [View all comments on this section]
Comment ID 16098881//1
Respondent Deleted User [View all comments by this respondent]
Agent ian jewson
Response Date 30 Oct 2017
Comment

SITE ALLOCATIONS PLAN EXAMINATION: Proposed Modifications Consultation to the Site Allocations Plan

I am writing on behalf of our client, Nailsea Holdings LVA LLP, in respect of the above consultation. This follows similar submissions sent to the Council in August 2017.

In the first instance our client welcomes the removal of land North of Greenfield Crescent and Woodland Road, Nailsea as proposed Strategic Open Space (community facilities).

This representation covers the following matters:

1. The LPA’s decision not to undertake the work requested in the note from the Inspector following the closure of hearings on 18th May 2017.

2. The LPA’s approach to identifying potential new housing allocations.

The key reason that the LPA was unable to identify sufficient sites to meet the 2,500 dwelling requirement is the methodology that they have used, specifically:

1. The LPA has decided to exclude sites where an application or pre-application request was not submitted before 18th May 2017.

2. The LPA has decided to exclude any sites that do not fully comply with the Core Strategy. Despite the Inspector noting at paragraph 23 of ID4 that:

"A further potential constraint to the identification of additional allocations is the distribution of housing identified in Policy CS14. However, CS14 refers to the “broad distribution of new dwellings” which indicates that the net additional dwellings listed in the policy do not constitute a straight jacket to be achieved, and that there is some flexibility for the distribution of housing provision within the settlement hierarchy in the CS."

This methodology has resulted in the LPA discarding a number of sites that could enable them to achieve the 2,500 dwelling requirement.

At paragraph 22 of the note issued on 18th May 2017 (ID4) following the closure of hearings the Inspector states:

“I consider that the Council should test the potential for the provision of up to 2,500 additional houses in order to identify the environmental costs of allocating a wider choice of housing sites. Furthermore, where new allocations are to be made, there is a need to identify and allocate sites which can be made available for development at an early date to help meet the five year supply as well as secure the overall delivery of the housing requirement by 2026."

The instructions from the Inspector were clear and unambiguous. We were therefore extremely disappointed to note from the LPA’s interim response (CD2) to the Inspector that they decided not to undertake the work that was requested.

Firstly, at paragraphs 7 to 16 of CD2 the LPA attempt to reopen discussion on the figure of 2,500 dwellings and make the case for a lower figure. This is inappropriate as it is not within the scope of work requested by the Inspector, and is clearly an attempt to row back on what was agreed during the hearing sessions.

Secondly, the LPA has not tested the “potential for the provision of up to 2,500 additional houses”. Even if all of the 28 sites on which the LPA sought comments on in August had been deliverable by 2026, they would have only delivered a total of 1,812 dwellings. This falls significantly short of the figure of 2,500 dwellings that the LPA was asked to test.

2. The LPA’s approach to identifying potential new housing allocations

The key reason that the LPA was unable to identify sufficient sites to meet the 2,500 dwelling requirement is the methodology that they have used, specifically:

1. The LPA has decided to exclude sites where an application or pre-application request was not submitted before 18th May 2017.

2. The LPA has decided to exclude any sites that do not fully comply with the Core Strategy. Despite the Inspector noting at paragraph 23 of ID4 that:

"A further potential constraint to the identification of additional allocations is the distribution of housing identified in Policy CS14. However, CS14 refers to the “broad distribution of new dwellings” which indicates that the net additional dwellings listed in the policy do not constitute a straight jacket to be achieved, and that there is some flexibility for the distribution of housing provision within the settlement hierarchy in the CS."

This methodology has resulted in the LPA discarding a number of sites that could enable them to achieve the 2,500 dwelling requirement.

Conclusions and Recommendations

The removal of land North of Greenfield Crescent and Woodland Road, Nailsea as proposed Strategic Open Space (community facilities) is welcomed. However, the changes to The Proposed Modifications are insufficient to make the Site Allocations Plan sound. Specifically, the Plan has not been 'positively prepared' and is not 'justified', two of the tests of soundness set out at paragraph 182 of the NPPF.

In order to address this issue we strongly urge the Inspector to pause examination and advise the LPA that they need to undertake a more thorough site assessment process that identifies sufficient sites to address the significant shortfall in the LPA’s 5 year housing land supply, and ensure that they meet their overall housing requirement for the plan period.

 

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