Office use only.
Respondent rep no
Your name or organisation: …Bloor Homes……………………………………….
Please identify the part of the Core Strategy to which this representation refers:
Vision number (pages 15
– 18)
Priority Objective number (page 20)
Policy number (includes supporting paragraphs to policy)
Diagram i.e. Key Diagram, Inset 1 or Inset 2
Key Diagram (Key Diagram page 149)
Inset 1 (CS29 Weston-Super-Mare Town Centre page 115)
Inset 2 (CS30 Weston Villages page 126)
Policy Cs13 Scale of New
Housing, para – 3.178 – 3.201
You must complete a separate Part B of this form for each section, policy, or diagram on which you wish to comment.
Question 1: Soundness of the Core Strategy
(Please refer to accompanying guidance notes for meanings) a) Do you consider this part of the Core Strategy to be sound: Yes/ No
(i.e. do you support the Core Strategy) b) If you consider this part of the Core Strategy to be unsound, please identify which of the three test of soundness below your representation relates to. Otherwise go to questions 2 and
3.
Justified (based on robust and credible evidence, better than any reasonable alternatives) i) If you consider this part of the Core Strategy is unsound because it is not justified (based on robust and credible evidence, better than any reasonable alternatives) please explain why.
Policy CS13 identifies the general housing requirements of the District to 2026, setting out that land will be identified to deliver a minimum of 13,400 new dwellings in the authority. This figure is not consistent with paragraph 10 of PPS 3 because it does not take account of the identified need in either the Household Projections 2006 or 2008. Furthermore, the household projections show a trend of increasing demand for households, with the 2006 projections identifying a need for 33,000 new households, whilst the 2008 projections identify a need for an additional 36,000 new households, an increase of nearly 10%. The increase in North Somerset is set against a backdrop of
20,500 fewer households per year being formed in England between 2008 and 2031.
2.0
The evidence based provided by North Somerset Council seeks to justify a so called ‘new

The evidence based provided by North Somerset Council seeks to justify a so called ‘new locallyderived housing requirement for the district’. Paragraph 2.6 states that:
‘.......likely to be in the range 14,000 – 16,000 dwellings’ to be investigated and tested. This was put forward as a preliminary suggested range, based on an understanding of potential environmental capacity’.
The evidence base seeks to dismiss using the Household Projections because they are based on past trends, with a key problem for North Somerset being the historically low growth of employment that lagged behind population and housing demand. Paragraph 4.4 states that:
‘The need is to steer a middle path between limiting the provision of new housing strictly to a level required to just to house employees in new jobs projected in the local economy on the one hand, and simply just following some notion of market demand on the other.’
Paragraph 4.5 states that:
‘The method of setting the level of growth needs to follow the requirements for sustainable development but, at the same time, is realistic about the way the housing market operates in the real world. The solution it is suggested that the following principles be applied in addition to the formal Core Strategy vision…… a)‘Help ensure a healthy economy by closely linking housing growth to employment (employment led growth). b) Provide sufficient housing to meet needs arising locally through the delivery of mixed and balanced communities. This should allow for a stretching, but achievable, target for affordable housing provision and an adequate allowance for dealing with any current backlog of unmet need identified in the Council’s Strategic Housing Market Assessment (SHMA). c) Accept that the operation of market forces permits movement and freedom of choice for those with the financial means to exercise it; non economically active migrants will choose to move into the District and the pressures that this creates need to be recognised. d) Finally, identify and test identify alternative general total levels of housing and ascertain which options can be built within acceptable environmental limits following a critical assessment of environmental, infrastructure delivery and transport capacity, constraints and opportunities for mitigation. This requirement must be met from a subsequent exercise which takes on board the results of the SHLAA and
SA/SEA.’

The housing needs figure has been derived based on forecast job growth alone but at a lower level than forecast by Oxford Economics Projections. A recognised and accepted forecasting body in terms of forecasting employment trends. Based on the Modified Oxford Central projection, a need for
10,100 jobs is identified. This is then translated into a housing requirement drawing upon the
Household Projections 2006 but dismissing the figures based on the net international migration figures being too high due to the impacts of the recession going forward. However, to apply an assumption of zero net migration is considered unfounded and unrealistic to derive the housing need for the district.
The Council's approach to the Core Strategy is predicated upon the Household Projections 2006 being irrelevant due to the projections being based on past trends, particularly with regards to migration trends. PPS 3 requires that assessment of future requirements in local strategies should have regard to, amongst other factors, current and future demographic trends and profiles and take into account evidence including the Government’s latest published household projections.
Even if the above issues are set aside, Policy CS13 is fundamentally unsound and undeliverable.

ii)Please give details of the change(s) you wish to see and why you consider them necessary to make this part of the Core Strategy justified.
Please be as concise and precise as possible.
The deletion of Policy CS13 and it's rewriting on the basis on the need for a minimum of 22,780 homes being provided up to 2026, or the requirement of 36,000 identified in 2008 Household projections.
Through this approach the Core Strategy will reflect the guidance set out in PPS 1 and PPS 3 and ensure a sustainable and balanced distribution of housing development, providing for the whole needs of the District.
Effective (Deliverable, flexible and able to be monitored)
I) If you consider this part of the Core Strategy to be unsound because it is not effective
(deliverable, flexible and able to be monitored) please explain why. ii). Please give details of the change(s) you wish to see and why you consider them necessary to make this part of the Core Strategy effective. Please be as concise and precise as possible.

Consistent with National Policy
If you consider this part of the Core Strategy to be unsound because it is not consistent with national policy please explain why
Providing for only 41% of the forecast need according to the Household Projections 2006, or for only 37% of the forecast need based on the Household Projections 2008, is not compliant with paragraphs 23, 26 and 32 of PPS1 and paragraphs 32, 33 and 38 of PPS3. Fundamentally, the housing requirement is not consistent with the Household Projections. The impacts of migration cannot be totally dismissed by assuming zero net immigration. The document therefore fails the test of Soundness requiring conformity with national planning policy as set out within PPS12.
At the very least the basis of future jobs should be based on the Oxford Economic Central Forecast of 17,000 additional jobs between 2006-2026, or even the Stronger Trend Growth of 21,700 considering the Authority’s objective of achieving the employment-led regeneration of the area.
Applying the Additional Homes jobs ratio as set out in Appendix 2 of Determining a locally derived
District Core Strategy Housing Requirement to 2026, Stage 2 Report of 1.33, this translates into a homes requirement of 22,780 homes based on the Oxford Economic Central Forecast, or a requirement of 28,140 homes based on the Stronger Trend Growth. Therefore, it is considered that a minimum of 22,780 homes should be planned for in the authority, if the household projections are to be dismissed due to the unproven assumption that migration will not continue at the previous rates due to economic recession. ii) Please give details of the change(s) you wish to see and why you consider them necessary to make this part of the Core Strategy consistent with national policy . Please be as concise and precise as possible
The deletion of Policy CS13 and it's rewriting on the basis on the need for a minimum of 22,780 homes being provided up to 2026, or the requirement of 36,000 identified in 2008 Household projections.

Please note your representation should cover succinctly all the information, necessary to support/justify the representation and the suggested change, as there will not normally be a subsequent opportunity to make further representations. After this stage further submissions will only be at the request of the inspector, based on the matters and issues he/she identifies for examination.
Question 2: Examination a) Can your representation seeking a change be considered by written representations, or do you consider it necessary to participate at the examination hearing? Please note: written representations carry as much weight as attendance at a hearing and will be given equal consideration.
Written Representations
Attend Examination Hearing X b) If you wish to participate at the examination hearing please outline why you consider this to be necessary i.e. how it would add to your representation.
It is considered important to be present at the Examination to explain fully to the Inspector our
Client’s concerns in relation to the Soundness of the Core Strategy and answer any point of clarification with regards to the Client’s site that is being promoted for development.
Please note: The inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the examination hearing.
Question 3: Legal Compliance
Do you consider the Core Strategy Publication Version to be legally compliant? (Please refer to accompanying guidance notes for meanings)
Yes/ No
If you have answered no to this question, please state why:

Signature…………………………………………… Date……………………