Office use only.
Respondent rep no
North Somerset Council
Core Strategy
Publication Version February 2011
.
Representation Form
In completing this representation you are providing a formal consultation response
under Regulation 27 of the Town and Country Planning (Local Development)(England)
Regulations 2008. Please note that your name and comments (and organisation where
applicable) will be made publicly available.
This form has two parts:
Part A Personal details.
Part B Your representation. Please complete separate copies of Part B for each vision,
objective, policy, or diagram against which you wish to comment.
Guidance notes are available which explain the meaning of “Soundness” and “Legal
Compliance”. If you believe a part of the document to be unsound with regard to more than
one policy etc, please provide a separate representation (separate copies of Part B) for each
comment you wish to make.
Comments relating to the Sustainability Appraisal should be submitted separately.
Completed forms must be received by midnight 23 March 2011.
Email to: planning.policy@nsomerset.gov.uk
Post to:
Planning Policy Team,
North Somerset Council,
Somerset house,
Oxford Street,
Weston- super- Mare
BS23 1TG
Part A Personal details
You will only need to complete this part once for all comments made. You need to supply the
following information in order for you representation to be valid (duly made).
Personal Details
Agents Details (if applicable)
Miss
Title
Initial
E
Z
Last Name
Vashi
Abberley
Bloor Homes
Barton Willmore
Street Address
3 Stratton Court
Greyfriars House
Village
St Marsden Park
Greyfriars Road
County
Swindon
Cardiff
Postcode
SN3 4YH
CF10 3AL
Daytime Telephone No.
01793 835600
02920 660910
Organisation
(where
relevant)
Town
Email Address
elaine.vashi@bloorhom zoe.abberley@bartonwill
es.com
more.co.uk
You only need to complete this page once. If you wish to make more than one representation,
attach additional copies of Part B to this part of the representation form.
Office use only Response 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)
X
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)
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.
The Vision is not considered to be justified due to how the housing numbers have been
derived and then distributed. For more detailed information, please see Representatio n
Form in relation to Policy CS13 Scale of Hew Housing and Policy CS14 Distribution of
New Housing.
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.
Please see Representation Form in relation to Policy CS13 Scale of Hew Housing and
Policy CS14 Distribution of New Housing.
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
Visions 1-6
We object to the overall Vision for North Somerset set out in Visions 1-6. Fundamentally the
Visions do not reference the need to meet the housing requirements of the District to 2026 based
on the Household Projections published by CLG.
In particular it is noted in Vision 2 that Weston Super Mare is identified for major employment
growth. However no reference is made to the need to deliver new housing in order to achieve
this Vision.
Similarly the Visions for Clevedon, Nailsea and Portishead (Visions 3-5) are identified as meeting
the needs of their population and playing less of a Dormitory role as a local service centre.
However these settlements clearly have a greater role to play and should also be a focus for
development. Accordingly the Visions for the three towns (Visions 3-5) are overly restrictive and
do not reflect the requirements of paragraph 38 of PPS3 by concentrating growth on Westonsuper-Mare.
We also submit that Yatton should be identified alongside Clevedon, Nailsea and Portishead due to
its range of services, employment, housing and accessibility by modes of transport other than the
private car – particularly by rail. On this basis Yatton should be identified as being a suitable
location to assist in meeting the housing and employment needs of the rest of the District to 2026,
rather than a service village.
Finally in respect of the infill villages and countryside, the Vision is overly restrictive and sets these
smaller villages and towns in “aspic”.
This Vision will therefore not allow the delivery of
sustainable, viable and long term prosperous communities within the rest of the District outside of
Weston Super Mare or Clevedon, Nailsea and Portishead. With reference to Vision 6 we object to
the inclusion of Yatton within the Service Villages Vision as the town has a range of services,
employment, housing and is accessible by modes of travel other than the private car (particularly
by rail) and would be appropriate for the provision of additional housing and employment to assist
in meeting the needs of the authority to 2026.
It is therefore clear that Visions 1-6 fail to meet the requirements of PPS1 at paragraph 32, PPS3
at paragraph 38 and PPS12 paragraph 4 which require the delivery of a Vision which sets out
clearly how the District will deliver housing and all other development over the lifetime of the Plan.
Additionally it is clear that Visions 1-6 do not meet the requirements of PPS1, PPS3 and PPS7.
Accordingly Visions 1-6 fail the test of conformity with national planning policy guidance as
required by PPS12.
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.
Visions 1-6 should be modified to reflect the household projections and to ensure conformity with
PPS1, PPS 3 and PPS7.
Yatton should also be identified under Policy CS31 as a suitable location for additional housing,
employment and other development due to its range of services, employment, recreation facilities
and accessibility by modes of travel other than the private car – particularly by rail.
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……………………