Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Employment Q36. What role do you think that residential developers should play in helping to deliver employment? Should the specific link between housing and employment be maintained. [View all comments on this section]
Comment ID 14590529//13
Respondent Persimmon Homes Severn Valley [View all comments by this respondent]
Response Date 10 Dec 2018
Comment

Section 6 of the document rightly sets out the economic objective of sustainable development from the NPPF. Section 6 of the NPPF sets out further guidance on how this should be reflected in planning policies.  Specifically planning policies should:

set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to local industrial strategies and other local policies for economic development and regeneration.’ 

We consider this should form the starting point for reviewing the employment-led policy at Weston-super-Mare and how it would now relate to the new Local Plan Strategy for growth and development in North Somerset. We note that both garden villages and the expansion of Nailsea include employment proposals.  How will the delivery of employment at these locations relate to delivery at Weston-super-Mare where the employment-led policy prioritises delivery of employment?  Equally will the employment-led policy at Weston-super-Mare slow down residential growth there but enable unrestricted residential growth at the new locations?  If that happens will it encourage unsustainable residential commuter patterns at these new locations? 

In our view in considering these issues the new JSP and Local Plan Strategy for North Somerset fundamentally changes how the employment-led policy at Weston-super-Mare will need to operate in the future. This is because the Core Strategy Policy is an employment-led policy for the district not just Weston-super-Mare but that additional policy requirements are set out for Weston-super-Mare in the context of and to implement the Core Strategy.  This needs to be addressed in the Local Plan and it cannot be dismissed as a long-term issue, because the trajectories for the strategic development areas in the JSP show North Somerset will be relying on housing numbers from the new locations from 2024/25 or in other words year 5 of the next 5 year housing land supply period.

In addition in the context of the Core Strategy the majority of new residential development was proposed in Weston-super-Mare, which provided the opportunity to pursue an employment-led housing policy there. In the context of the JSP and the new Local Plan, the majority of the new residential development is outside Weston-super-Mare in the strategic development locations.  Therefore it is inappropriate to retain a restriction on the residential development in Weston-super-Mare largely on existing commitments, and leaving residential development to come forward in the SDL’s with no link to employment provision.  In the context of the JSP a different policy would be operating in Weston-super-Mare compared with the whole of the West of England.

The JSP also suggests a need for more flexibility in employment policy rather than continuation of the current policy linking provision to office use. Paragraph 23 of the submitted JSP says ‘the continued changes in the employment market mean that flexibility is required in the employment land portfolio, in order to response to changes in market demand during the plan period and beyond.’  This points to a market-led approach without policy restrictions on any part of the market within the JSP area.  It requires an approach which recognises the positive role residential developers have in unlocking employment opportunities and delivering infrastructure, rather than applying a jobs/home formula.

Employment – Comments on Employment Land Review

The Employment Land Review concludes that the drivers of the employment-led approach were reasonable, but this is in the context of the existing policy context. It also says the majority of the rest of the district is less suitable for employment growth, but that has now changed in emerging policies which propose new employment provision in the new development locations proposed in the JSP and the emerging Local Plan.  Whilst improving self-containment in Weston-super-Mare was an important aim previously, it is even more important to plan for self-containment in the new locations from the outset, otherwise they will become commuter settlements. 

The Employment Land Review also raises questions about whether the scale of employment development is deliverable at Weston-super-Mare where we consider the emphasis on B1 office development causes more problems. In particular there is no demand for the quantum of office use needed to meet the policy and that the strongest element of demand in North Somerset to 2036 is likely to be for B8 uses, but a split between office and warehouses is unlikely to meet the requirements of the policy in the plan period. 

Whilst the Employment Land Review also recognises that employment-led is a long-term policy this needs to be balanced by the fact that the housing shortage is short-term and the housing need continuous. The recognition in the Employment Land Review that the strategy is market dependent including wider macro-economic factors is important in considering the appropriate way forward.

The Employment Land Review recognises however that the policy has been implemented on a more flexible basis including through the Joint Position Statement. All of this demonstrates the policy must change.  The Employment Land Review then sets out a number of options which we comment on below:


Options from the Employment Land Review

 

Our Comments

A more flexible approach to jobs to allow a balance of employment types based on the overall scale that can be accommodated possibly site by site.

Our preferred approach would be dispense with the jobs to homes ratio as set out in the above comments, but if it is retained, a more flexible approach as described would be a necessity in order to ensure the continued delivery of both residential and employment development.

   

Reviewing types of jobs required against the context of supply and demand:

 

-       Targets per site

PHSV do not support because it merely continues existing problems by reducing flexibility.

-       Market driven

This would be helpful in allowing the market to rebalance employment supply in Weston-super-Mare from the impact of an interventionist planning policy approach.

-       Hybrid

Potential support for this approach subject to the precise wording of the criteria in the policy and including a cascade approach if there is a need to ensure that not all land could be developed for a particular use, all to be monitored by the Weston Villages Delivery Group

   

Reviewing the delivery mechanisms including the link to housing:

 

-       Longer time frame and re-phasing of employment to housing targets

Not appropriate in the context of adopting a hybrid policy as above.

-       Provision of land and premises through service sites/speculative provision

PHSV do not support this approach.

-       Re-planning and collaboration (currently in place but unsuccessful due to lack of certainty of delivery)

PHSV do not support this approach due to the failure of the existing policy.

-       North Somerset Council intervention

As set out in the Employment Land Review this depends on the ability of the Council to deliver and any restrictions attached to any policy on delivery of housing. Therefore PHSV does not support this approach.

 

Notwithstanding our preferred approach set out above, PHSV consider it is important that the Council continues to work with developers and landowners to deliver a policy and mechanism through the new Local Plan which allows the delivery of both housing and employment development without the need for a formulaic jobs per home approach.

Summary
Section 6 of the NPPF should form the starting point for reviewing the employment-led policy at Weston-super-Mare. In the context of the Core Strategy the majority of new residential development was proposed in Weston-super-Mare, In the context of the JSP and the new Local Plan, the majority of the new development is in the SDLs. It is therefore inappropriate to continue with the current approach.
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