Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Banwell Garden Village Q10. Do you have any comments on the proposed vision for Banwell? [View all comments on this section]
Comment ID 20338913//11
Respondent Aston [View all comments by this respondent]
Response Date 11 Jan 2019
Comment

Proposed Vision – Banwell is in an unsustainable location and viability has not been established.

For resources to be deployed by NSC if this land is to be assessed, evidence should be sought to demonstrate that land in the Garden Village is available to supply to the market for housing at the rates per hectare used in the viability modelling, namely £100k/ha to £250k per ha.

Unless land is forthcoming within the proposed garden village locations at these levels then no development will come forward, or the target affordable housing of 35% or more will not be achieved. The land will likely already secured under option agreements and evidence to substantiate the valuation figures used should therefore be sought from the relevant landowners by NSC.

More work is necessary on the abnormal cost associated with a garden village development. These will be substantial and include:

  • Off-site utility infrastructure reinforcement – power, water, gas, foul water and telecom.
  • New highway, cycle and public transport infrastructure including M5 connection.
  • Costs in connection with acquiring the land rights for new infrastructure routes.
  • The Highways Agency need to supply evidence that the proposed new Junction 21A is deliverable within the plan period to supply the required housing. History suggests that is unlikely. Highways England is currently working through a 30 year backlog of highway projects.

Each input will of course affect the development appraisal and viability.

Are compulsory purchase powers proposed to acquire and deliver the necessary infrastructure to deliver the target levels of housing within the 20 year plan period? What evidence is there that this can be achieved?

A 5% contingency for such early stage development costs is extremely light until feasibility studies are more advanced. 10-20% would be more reasonable.

The implications of Brexit on the sales projections and project finance rates needs to be carefully modelled and a wide variety of scenarios tested over a range of delivery timescales once the basic model has been satisfactorily completed. Evidence needs to be supplied to justify abnormal (very low) infrastructure and land acquisition costs.

The case has not been presented for all alternative scenarios including distributing the housing at the larger settlements by minor local adjustments to the Green Belt (GB) where the primary purposes of the GB are not significantly affected.

It is recognised that in the West of England JSP pre-examination exchange of letters with the Planning Inspectorate that further justification has been supplied for the SDL locations and launched in an overlapping consultation 12.11.18 to 7.01.19 (WED 004 Justification of the SDLs). We will separately review and reply to this consultation.

No detailed planning can be undertaken without an up to date Strategic Flood Risk Assessment.

We appreciate this is initial scoping and not detailed design but OS based mapping would enable participants to recognise the locations of proposed housing, transport infrastructure etc. Please publish. The diagrams are not as helpful, particularly to engage local people effectively.

Summary
Unsustainable location and viability not established. Need to demonstrate land is available at £100-250/ha for viability modelling. More work needed on abnormal costs of garden village development - off-site utility reinforcement, new highway, cycle, public transport infrastructure, costs of acquiring land for infrastructure, evidence that J21a is deliverable. Will CPO be used? Implications of Brexit on sales and project finance? Need to present case for all alternative scenarios.
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