West of England Joint Spatial Plan: Towards the Emerging Spatial Strategy

Joint Spatial Plan: Emerging Spatial Strategy

Responses

List of answers to the specified question
NameOptionTextDate
Mr. and Mrs. Sperring C/O Alde… See attached. 19 Dec 2016 22:49
South West Strategic Developme… See separate Representations Document. 19 Dec 2016 17:54
A. J. and G. G. Thomas The JSP states that the Objectively Assessed Need is 105,000 dwellings across the period 2016 to 2036. The WEP will need to consider a number of key issues that will limit and inhibit the deliverability of Strategic Sites throughout its wider housing market area. These issues include transport; sustainability and Green Belt.

Bristol is the economic driving force within the West of England and as such people seek to live in or near the City. The most sustainable locations are therefore City Fringe areas or Higher Tier Settlements.

In South Gloucestershire the most sustainable locations are constrained by the existing Green Belt Designation. Therefore when assessing locations for development, the Council must decide whether to deliver the Full Objectively Assessed Need (FOAN) for housing or seek to contribute to FOAN up to a level that can be delivered without eroding specific Policy Designations or harming the specific environment within its Authority area.

FOAN and housing targets may differ if Authorities decide that Policy constraints and Natural Environment are so constraining that it is not possible to deliver the required housing. The West of England SHMA establishes FOAN at between 100,000 and 105,000 dwellings, the JSP sets the housing target at 105,000 dwellings and the Local Authorities have increased provision of housing from 85,000 to 105,000 dwellings. Independent Planning Representations indicate that this is an under-estimate and suggest that numbers should be increased further.

Commitment to additional new housing alone doesn’t give any indication about how meeting local needs will be balanced with meeting the wider Bristol area’s housing needs, especially when considering the strategic issues of poor transport connections and the lack of Public Transport options available for most outside of the principle urban areas.

The West of England Partnership must be encouraged to redress the issues presented by both NLP and Barton Wilmore that include expected impacts from uplift in employment growth derived from the
success of following the JSP to fruition. It is a continual process where planned increase in job activities lead to planned job growth.

In this context the 105,000 target is not, in our view, the FOAN.

The JSP is clear that it is seeking to deliver housing in the most appropriate locations for growth based upon a Strategy supported by three key aims:

- A concentration of development within the urban areas;

- Transport focus;

- The protection of the Green Belt.

This is fundamentally flawed.

The NPPF places a requirement on Council’s to prioritise development in the most sustainable locations.

The WEP is now faced with a more challenging FOAN than the previous Issues and Options Consultations have provided and so the Spatial Strategy must demonstrate how it is going to meet fully the Objectively Assessed Housing Need and the Plan should prioritise three key aspects:

- Allocating sites that are in the most sustainable locations;

- Delivering an appropriate amount of housing including Affordable Housing;

- Providing a suitable mix of houses within the context of local need.

The Need to Achieve the Wider Bristol Area Minimum Targets for Housing Delivery:

The JSP should identify a mix of sites to meet the tests of Soundness with a justified target for housing that meets local needs and Affordable Housing needs. Not to do so will undermine the JSP and Proposals within the JTS (Joint Transport Strategy).

To ensure deliverability JSP should identify and allocate additional locations to seek to increase flexibility of supply including a proportion of Greenfield Land within the Green Belt to ensure that the Local Plan is sufficiently flexible to ensure delivery.

The wider Bristol history of under delivery against the existing Local Plan targets compounds concerns over deliverability. The SHMA confirms that “there is likely to be a backlog of 4,019 dwellings between 2012 – 2016 that will need to be addressed during the 20 year Plan Period 2016 – 2036.”

Councils should ensure that additional sites are identified and allocated to provide flexibility for non-delivery of other sites. Without which the risk of non-delivery is compounded.

We contend that there is real risk that locations identified in Topic Paper 1: The Formulation of the Emerging Spatial Strategy will be undeliverable. The suggestion is that land currently located within the Green Belt will be automatically discounted as unsuitable for development when assessed by the JSP Green Belt Stage 2 Assessment (2015 Supporting Document).

Previously developed sites are generally less deliverable than Greenfield Land due to the complications associated such as availability, existing use values and abnormal costs. Relying on Brownfield Land to seek to achieve the Spatial Strategy housing targets presents a very real risk of non-delivery even against the minimum targets.

The NPPF Framework now requires Local Authorities to identify and update annually a supply of specific deliverable sites within an additional 5% buffer moved forward from later in the Plan Period to ensure choice and completion in the market for land. This supports the argument for flexibility.

The NPPF also urges Local Planning Authorities to identify a supply specific, developable sites or broad locations for growth for years 6 – 10 and where possible for years 11 – 15 of the Plan Period. Whilst the JSP is planning for 20 years of a Plan Period, beyond the advice of the NPPF. However, in principle a longer Plan requires greater flexibility in delivery methods which at the moment is not demonstrated.

The Spatial Plan should allocate development within appropriate locations within the Green Belt and commission a further review of sites put forward within the Green Belt which are suitable for housing. When understanding the contribution that these sites can achieve in supporting sustainable development and assisting with delivery of much needed housing a judgement can be made on the contribution to achieving the objectives of the Spatial Strategy.

Land located North of High Street, Iron Acton, South Gloucestershire is sensibly located within close proximity to employment and can be utilised for the delivery of new homes.

Failure to take account of this site’s availability would result in an inflexible and non-deliverable Plan. Adjusting the housing target to achieve a level of housing that better reflects the FOAN is required to support the Examination in Public.

Housing Mix:

Not all sites will be capable of delivering the mix of units required to deliver a mixed and balanced community as required by the NPPF. To overcome this the JSP should seek to allocate a range of sites including Green Belt that is located sustainably.
24 Jan 2017 16:45
A. M. James No, the strategy is neither robust or far-reaching enough to properly tackle the housing needs of the area. The binary approach of the strategy that urban areas are for growth and the natural landscape is for enjoyment is too simplistic and overlooks the diverse settlement pattern and the importance of the rural hinterland for housing and employment as well as recreation! The strategy singularly fails to respond to the dearth of housing in rural areas especially the chronic shortage of affordable housing. This issue is prevalent throughout the area so there is a pressing need to take a strategic approach. With the constraint posed by the Green Belt the strategy must take a proactive approach to development in villages beyond the designation otherwise rural affordable housing will not take place and these settlements will simply stagnate. 14 Dec 2016 20:57
A. N. Simmonds I understand that the plan envisages adding 800.more dwellings to
Backwell over a 10 year period, which, would represent a 50% increase in the number of households. Also, the plan, apparently, treats Nailsea and Backwell as being a 'Sub-Region : rather than as distinct communities with their own characteristics and needs.

According to the newsletter, the Spatial Plan shows just 10 strategic
Development locations' for the whole of the West of England, including 3 in North Somerset alone.
30 Jan 2017 09:34
A. T. Bennett & Sons (Mr. Bennett) The JSP states that the Objectively Assessed Need is 105,000 dwellings across the period 2016 to 2036. The WEP will need to consider a number of key issues that will limit and inhibit the deliverability of strategic sites throughout its wider housing market area. These issues include transport; sustainability and Green Belt.

Bristol is the economic driving force within the West of England and as such people seek to live in or near the City. The most sustainable locations are therefore City Fringe Areas or Higher Tier Settlements.

For example South Gloucestershire have identified the North East Fringe of Bristol and Yate as locations that perform excellently when measured against Sustainability Criteria.

In South Gloucestershire the most sustainable locations are constrained by the existing Green Belt Designation. Therefore when assessing locations for development, the Council must decide whether to deliver the Full Objectively Assessed Need (FOAN) for housing or seek to contribute to FOAN up to a level that can be delivered without eroding specific Policy Designations or harming the specific environment within its Authority area.

FOAN and housing targets may differ if Authorities decide that Policy constraints and Natural Environment are so constraining that it is not possible to deliver the required housing. The West of England SHMA establishes FOAN at between 100,000 and 105,000 dwellings, the JSP sets the housing target at 105,000 dwellings and the Local Authorities have increased provision of housing from 85,000 to 105,000 dwellings. Independent Planning Representations indicate that this is an under estimate and suggest that numbers should be increased further.

Commitment to additional new housing alone doesn't give any indication about how meeting local needs will be balanced with meeting the wider Bristol area's housing needs, especially when considering the strategic issues of poor transport connections and the lack of Public Transport options available for most outside of the principle urban areas.

The West of England Partnership must be encouraged to redress the issues presented by both NLP and Barton Wilmore that include expected impacts from uplift in employment growth derived from the success of following the JSP to fruition. It is a continual process where planned increase in job activities lead to planned job growth.

In this context the 105,000 target is not, in our view, the FOAN.

The JSP is clear that it is seeking to deliver housing in the most appropriate locations for growth based upon a Strategy supported by three key aims:

• A concentration of development within the urban areas;

• Transport focus;

• The protection of the Green Belt.

This is fundamentally flawed.

The NPPF places a requirement on Council's to prioritise development in the most sustainable locations.

The WEP is now faced with a more challenging FOAN than the previous Issues and Options Consultations have provided and so the Spatial Strategy must demonstrate how it is going to meet Fully the Objectively Assessed Housing Need and the Plan should prioritise three key aspects:

• Allocating sites that are in the most sustainable locations;

• Delivering an appropriate amount of housing including Affordable Housing;

• Providing a suitable mix of houses within the context of local need.

The Need to Achieve the Wider Bristol Area Minimum Targets for Housing Delivery.

The JSP should identify a mix of sites to meet the tests of soundness with a justified target for housing that meets local needs and Affordable Housing needs. Not to do so will undermine the JSP and Proposals within the JTS (Joint Transport Strategy).

To ensure deliverability JSP should identify and Allocate additional locations to seek to increase flexibility of supply including a proportion of Greenfield Land within the Green Belt to ensure that the Local Plan is sufficiently flexible to ensure delivery.

The wider Bristol history of under delivery against the existing Local Plan targets compounds concerns over deliverability. The SHMA confirms that "there is likely to be a backlog of 4,019 dwellings between 2012 - 2016 that will need to be addressed during the 20 year Plan Period 2016 - 2036."

Councils should ensure that additional sites are identified and Allocated to provide flexibility for non-delivery of other sites. Without which the risk of non-delivery is compounded.

We contend that there is real risk that locations identified in Topic Paper 1: The Formulation of the Emerging Spatial Strategy will be undeliverable. The suggestion is that land currently located within the Green Belt will be automatically discounted as unsuitable for development when assessed by the JSP Green Belt Stage 2 Assessment (2015 Supporting Document).

Previously developed sites are generally less deliverable than Greenfield Land due to the complications associated such as availability, existing use values and abnormal costs. Relying on Brownfield Land to seek to achieve the Spatial Strategy housing targets presents a very real risk of non-delivery even against the minimum targets.

The NPPF Framework now requires Local Authorities to identify and update annually a supply of specific deliverable sites within an additional 5% buffer moved forward from later in the Plan Period to ensure choice and completion in the market for land. This supports the argument for flexibility.

The NPPF also urges Local Planning Authorities to identify a supply specific, developable sites or broad locations for growth for years 6 - 10 and where possible for years 11 - 15 of the Plan Period. Whilst the JSP is planning for 20 years of a Plan Period, beyond the advice of the NPPF. However, in principle a longer Plan requires greater flexibility in delivery methods which at the moment is not demonstrated.

The Spatial Plan should Allocate development within appropriate locations within the Green Belt and commission a further Review of sites put forward within the Green Belt which are suitable for housing. When understanding the contribution that these sites can achieve in supporting sustainable development and assisting with delivery of much needed housing a judgement can be made on the contribution to achieving the Objectives of the Spatial Strategy.

Land such as Says Court Farm is sensibly located within close proximity to employment and can be utilised for the delivery of new homes. The site is of significant size and can deliver a mix of appropriate residential development in one of the most sustainable locations across the whole JSP area.

Failure to take account of this site's availability would result in an inflexible and non-deliverable Plan. Adjusting the housing target to achieve a level of housing that better reflects the FOAN is required to support the Examination in Public.

Housing Mix:

Not all sites will be capable of delivering the mix of units required to deliver a mixed and balanced community as required by the NPPF. To overcome this the JSP should seek to Allocate a range of sites including Green Belt that is located sustainably.
03 Jan 2017 15:14
Abbey Manor Group Limited (Jud… The buffer of 2% is probably insufficient to cater for the difference between the estimate of need and the outcome of the updated SHMA's 19 Dec 2016 17:59
Abbots Leigh Parish Council (M… The Parish Council welcomes the emerging Joint Spatial Plan and Its Vision, Priorities and Key Spatial Implications. In particular we welcome the emphasis given to priorities for maintenance of the Green Belt, provision of affordable housing, addressing unsustainable commuting patterns and maintenance/enhancement of environmental quality. 12 Jan 2017 09:06
Adam Silcock It makes provision for the housing but is this in the right areas?? The development of filton airfield to be a strong business area suggests that homes near this would reduce the number of vehicles needed to be able to get to work and back. If all of the new homes are miles away, the traffic in the area increases. 18 Dec 2016 18:41
Adam Smith No not by building in Charfield. I am in my 20s and will be one of those people looking for housing in a few years. I work in Bristol and commute by car every day. You could not live in Charfield without a car in its current state. There is no public transport to major towns and cities for commuters. There is no adequate employment in Charfield and only those owning cars would be able to live here. I do not believe the proposed strategy is correct in including Charfield as a Tier 2 location for building 1000 houses. 18 Dec 2016 21:13
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