Office use only.
Respondent rep no
Part B Your representation
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)
Policy Cs20 Supporting A Prosperous
Economy Para – 3.244 – 3.264
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)
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.
We object to Paragraph 3.261 which states that development contributions will be sought towards
an Employment Investment Fund. Such funds should only be sought if it does not impact on the
viability of the proposed development taking into account any other potential contributions. The
suggested contribution would also fail the tests of Circular 05/2005 as: it is unspecific because it
can not be guaranteed that the contribution would deliver jobs; there is no detail on how it would
support employment development; there is no explanation how the proposed contribution would
be related to the scale of proposed development and there is no information on how the
contributions would be managed and who would use it.
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.
We propose that paragraph 3.261 is deleted.
We also propose the deletion of the reference to local needs only in the Policy box
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.
We note that paragraph 3.252 advises that:
“The Core Strategy seeks to reinforce this principle
through ensuring that new housing is provided in step
with job growth, that the existing backlog is addressed
over the plan period. This will be achieved by the delivery
of 1.5 use class jobs for every new dwelling at Westonsuper-Mare.”
We object to this approach as it is firstly imprecise, because it is not clear whether this statement
relates to:
1. Gaining planning permission for employment floorspace of a set quantum i.e. 100
homes and a consent for a building with sufficient space to deliver 150 jobs;
2. A requirement to build speculatively an employment building to release a set quantum
of housing; and
3. Employing 150 people directly to deliver 100 new homes.
Secondly the proposed phasing approach is fundamentally flawed because a housing developer
can bring forward housing sites, but they can not guarantee the delivery of new employment.
Housing developers can only provide planning permission or serviced sites for employment
development. The only time employment could be delivered in phasing with housing is where a
tenant has been secured in advance of the construction of housing. However in the absence of a
tenant it is simply not viable to speculatively build employment floorspace.
Speculatively building an employment unit at the outset of any development, in order to complete
a proposed housing development is considered to be highly likely not to be commercially viable, as
the up front costs are likely to be too significant and based on past trends even when the market
was buoyant, the level of demand was not sufficient for lenders / banks to release funding for
development of this form in Weston-Super-Mare. Lenders are going to be even more cautious
going forward.
Whilst it may be possible to secure funding for commercial development on the basis of an agreed
occupier to take up that floorspace (a pre-let), assuming the terms render the development viable,
with speculative development, by its very nature, there is no occupier in place and the development
is undertaken in the hope that an occupier can be found. However, there is no guarantee that an
occupier for such speculative building could be found.
Even at the peak of the market, speculative building for commercial purposes was considered to be
“high-risk” and as a result, many speculative developments have remained unoccupied throughout
the UK, resulting in significant problems for banks, financers and developers.
Therefore, if such problems and risks were associated with speculative development in the “sunny
upland” years, it is highly improbable that such speculative development could occur in the
economic climate we all currently experiencing and with levels of growth not predicted to reach the
pre-recession levels for some time, the policy will have a significant impact on the deliver of housing
in the authority.
Fundamentally, no developer can guarantee the delivery of jobs on an employment site or building.
Even if the developer could speculatively build an employment building, there is no guarantee that
an occupier would be delivered to the site and deliver the required level and number of jobs.
The provision of employment space should be based upon a market led approach. Through
providing employment development as a speculative development, it is unlikely to fully predict the
needs of specific potential occupiers. Many businesses are looking to purchase land or prefer design
and build opportunities rather than existing or newly built premises when expanding as they are
better able to ensure the premises fit their business needs. This can also have the benefit of
encouraging other businesses to look at the area as they see business investment happening, rather
than empty buildings going up. Speculative employment developments, other than those funded by
the public sector as at, are struggling to raise private sector funding due to the state of the market
and economy and are liable for full business rate charges if remaining empty after development.
These current issues are discouraging further speculative development and are likely to-do so for
the foreseeable further.
Additionally even if an employment building could be delivered on a speculative basis, the policy has
nil effect if the building stands empty due to a lack of a tenant.
Thirdly, setting aside the viability issues, there are fundamental, practical planning questions on
the ability to deliver 1.5 jobs per home, which include:

What is the definition of a job? Does this equate to part time jobs, full time jobs, or
full time equivalent jobs?

Would a “job” equate to a new job created directly in a place of employment? In
which case, what if the occupier / job were relocated from elsewhere in the UK
outside of North Somerset, or even Weston-super-Mare?

How is the provision of 1.5 jobs to be measured? It is not possible or practical within
planning to measure this or even enforce this.

Would this only apply to permanent jobs? Jobs may well arrive at the employment
site, but the nature of employment is such that, over time, a particular employer /
occupier may reduces staff numbers, close an office, or relocate elsewhere.
It
therefore cannot be guaranteed that the jobs will be retained on the site?

The construction of the housing and employment development itself will provide
employment directly, as well as provide indirect / knock-on benefits to the local
economy through contractors or building product suppliers.
How is this to be
measured or taken account of?

It does not take account of the increasing proportion of people who now work
remotely from home or are self employed working from their own homes and who do
not require business premises.
The approach advocated by the Core Strategy is therefore entirely unworkable and impractical, as
well as being wholly inappropriate and undeliverable.
We also object to the proposed paragraph as it ignores the very significant and valuable range of
jobs which are provided outside of the B category sectors within the retail, leisure, tourism,
medical, education, community/social care fields which are very significant elements of the
economy and deliver very significant employment levels and economic prosperity. The paragraph
and suggested approach is therefore fundamentally unsound for this reason.
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.
We propose that Yatton should be identified as a location suitable for the delivery of
additional employment development for up to 10 ha of B1, B2 and B8 uses.
The policy requiring 1.5 jobs per home is deleted and employment land should be delivered
through a market led approach.
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
The Core Strategy seeks to provide at least 10,100 additional employment opportunities 2006 –
2026, including around 114 hectares of land for B1, B2 and B8 uses. However over 80 hectares is
proposed to be provided within Weston Super Mare with only limited opportunities for infill
development upon largely previously developed land within Portishead, Clevedon and Nailsea.
This approach clearly denies the opportunity to deliver economic development and prosperity to
the rest of the District. This is completely out of alignment with the Government’s objective for
economic growth and prosperity set out within PPS4 (paragraph 10) which is to:
“Build prosperous communities by improving the economic performance
of cities, towns, regions, sub-regions and local areas, both urban and
rural.”
The Core Strategy therefore fails to follow the guidance of PPS4 and ensure the delivery of
Prosperous communities and economic development across the whole of the District.
As identified earlier and in respect to our representations on Policy CS23, we consider that Yatton
should also be identified under this policy, as it complies with the requirements of this settlement
category as it: has an existing employment base and potential for further growth; has a range of
services and facilities and is accessibility by modes of travel other than the private car.
We also object to the Policy because with regards to the Remainder of North Somerset it is limited
to meeting local needs. This does not comply with the requirements of PPS4 which seeks to
deliver employment opportunities. Accordingly it is not appropriate for the Core Strategy to
suggest that these settlements should only meet local employment needs.
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
We propose that Yatton should be identified as a location suitable for the delivery of
Additional employment development for up to 10 ha of B1, B2 and B8 uses.
We propose that the reference to only meeting local need in the rest of the District and the three
towns is deleted.
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……………………