Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Introduction How the housing requirement will be met: [View all comments on this section]
Comment ID 21425793//4
Respondent Newland Homes [View all comments by this respondent]
Agent ian jewson
Response Date 10 Dec 2018
Comment

A number of comments are raised in relation to the general approach taken by the Council as well as specific aspects of the Introduction section of the Issues and Options document. Overall it has been difficult to provide feedback due to the unknown position relating to the West of England Joint Spatial Plan (JSP) and the lack of background evidence on housing and employment growth which would help be useful context.

The Introduction section of the Issues and Options document should properly acknowledge the current policy context for North Somerset which is not fully expressed. The Core Strategy was originally adopted in April 2012 but following a successful legal challenge, policies were remitted to the Secretary of State for further examination.

Following a further Examination into Policy CS13, a modification was made to that policy raising the housing requirement to a minimum of 20,985 homes (or 1,049 dwellings per annum). The Inspector at the time recognised the limitations of the evidence base but found Policy CS13, as modified, sound subject to there being a review in the short term based on an up-to-date full objectively assessed need for housing.

The Core Strategy (January 2017) confirms at paragraph 1.13 that "In addition to annual monitoring a review of the level of new homes required will take place by 2018.". This is also specifically stated within Policy CS13: Scale of New Housing. The supporting text states that:

"3.178 To assess the performance of the Core Strategy, a separate monitoring framework has been prepared which sets out the key indicators. Where policies are not performing as intended, the AMR will suggest the actions that need to be taken to address the issues. In addition to annual monitoring a review of the level of new homes required will take place by 2018. The requirement for a review in 2018 is set out in policy CS13.

3.179 Plan preparation and the determination of the appropriate level for the district housing requirement took place against an uncertain planning context in terms of regional planning, the localism agenda, and the introduction of the NPPF, as well as a severe economic downturn  which raised doubts about the robustness of trend-based projections and economic growth assumptions.

3.180 The North Somerset housing requirement as set out in the April 2012 adopted Core Strategy was challenged in the courts and remitted back to the Planning Inspectorate for re-examination. As part of the reassessment of the housing requirement the Council undertook a fresh assessment of housing needs within the district.

3.181 A new joint Strategic Housing Market Area assessment for the wider housing market area was being carried out at the time that Policy CS13 was being examined. Until this work is completed the Council cannot move forward on the basis of a full objective assessment of housing need as required by the NPPF.

3.182 The provisions of this policy should therefore be seen as an interim position pending a review of housing requirements and provision which will be based on the findings of the new SHMA. The policy includes a specific reference to this review.

3.183 Other local authorities in the West of England are already committed to a similar approach. To reach a co-ordinated position between the West of England authorities based on the duty to co-operate, it is intended that the new SHMA will be published in June 2015. The processes are already in train to produce a Joint Strategic Planning Strategy by early 2017. This will be a formal development plan document and will, amongst other things, allocate housing provision between the West of England authorities. By early 2017 therefore the Council will be able to plan for a fully NPPF compliant and West of England agreed housing provision. Policy CS13 will be applied on the basis of that revised figure once it has been adopted. The Council will then need to review and have adopted a replacement plan, whether this be a Local Plan or a review of this Core Strategy, in order to put the requirements of the adopted JSPS into local effect.

3.184 If for any reason the JSPS has not been finalised the Council will move ahead with a review of the document on the basis of the best information available to it (including the NPPF compliant SHMA). In either case the review will be completed by the end of 2018 with a replacement for this policy being adopted by that time."

Paragraph 3.190 of the Core Strategy contains a commitment to review Policy CS13 by the production of a joint development plan by the West of England authorities with adoption by the end of 2018.

The above policy context is an important factor in shaping the new local plan and should be properly highlighted. The Introduction section of the Issues and Options document simply suggests (at page 3) that existing plans within the West of England authority area are required to be reviewed and updated alongside the West of England JSP. However, there is no acknowledgement that the review is overdue.

Duty to Cooperate

Paragraph 24 of the NPPF (2018) states that local planning authorities are under a duty to cooperate with each other. The Issues and Options document makes no reference to this duty and this should be addressed as soon as possible unless the Council considers that it does not relate to the local plan review process. If this is the case this should be explained for the benefit of any doubt.

Housing Requirements

It is widely acknowledged across the political spectrum that the UK is in the grip of a housing crisis. Nationally, the average house now costs eight times the average income. Whilst the causes of the housing crisis are complex, at the most basic level, as a nation we have not been building enough homes.

In June 2018 an appeal decision relating to at Weston Business Park, Laneys Drove, Locking, North Somerset BS24 8RA (Appeal Ref: APP/D0121/W/17/3184845) confirmed that the total five year supply of deliverable housing was 8,565 dwellings, or 4.4 years. It would appear that the Council’s existing housing policies are not working.

 In light of this it is disappointing that the Consultation Document has not highlighted the need to build more homes as the key issue facing the whole of North Somerset that the Local Plan must address.

Page 4 suggests that the starting point for the North Somerset local plan 2036 (NSLP 2036) is the proposed district apportionment from the JSP although this has yet to be tested at examination. The JSP has been in preparation since 2015. The examination has now been delayed until at least May 2019 and there is no certainty as to when the plan will be adopted. If the NSLP 2036 is to be informed by the JSP it should acknowledge that the document will need to change to reflect any consequential changes to the JSP and specifically the overall housing and employment requirement for North Somerset.

Whilst the Issues and Options consultation document suggests it is directly informed by the JSP the Council has not added relevant evidence to evidence base which supports the proposed need for 25000 homes to 2036. Whilst it is understood that this may have been prepared or the JSP for clarity it should do so. It should not assume that those commenting on the Issues and Options document has access to the evidence base for the JSP and more importantly should make it clear which documents are relied upon.

Page 4 of the Local Plan Review suggests that the starting point for the North Somerset Local Plan 2036 (NSLP 2036) is the proposed district apportionment from the JSP although this has yet to be tested at examination. The JSP has been in preparation since 2015. The examination has now been delayed until at least May 2019 and there is no certainty as to when the plan will be adopted. If the NSLP 2036 is to be informed by the JSP it should acknowledge that the document will need to change to reflect any consequential changes to the JSP and specifically the overall housing and employment requirement for North Somerset.

Whilst the Issues and Options consultation document suggests it is directly informed by the JSP the Council has not added relevant evidence to the evidence base which supports the proposed need for 25,000 homes to 2036. Whilst it is understood that this may have been prepared for the JSP, it should also be included for the NSLP 2036. It should not assume that those commenting on the Issues and Options document has access to the evidence base for the JSP and more importantly should make it clear which documents are relied upon.

The map at page 8 of the Issues and Options document identifies the constrained nature of North Somerset. This highlights that development will need to be accommodated in less constrained areas wherever possible. This should be the preferred approach but it will be important for the Sustainability Appraisal to consider all reasonable alternative development scenarios.

 

Summary
The Plan is premature and does not give sufficient emphasis on the delay in meeting the revised Core Strategy housing targets.
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