SOUTH GLOUCESTERSHIRE CORE STRATEGY EIP
Matter 7, Personal ID 3557665
Barton Willmore
7 – SPATIAL STRATEGY (CHAPTER 4), LOCATION OF DEVELOPMENT (CS5)
SUMMARY
Full answers to the questions posed by the Inspector are set our below.
To summarise, our
objections regarding the Proposed Spatial Strategy and location of development relate to th e
following issues:
- The overall number of dwellings proposed are insufficient to meet housing needs and
support economic growth, therefore additional ho using needs to be identified within
the Core Strategy;
- The housing that has been identified within the Core Strategy is focused on the main
settlements but the assumed build rates are optimistic and are not deliverable;
- Some sites that could deliver housing in the early part of the Plan are unnecessarily
phased to the back end of the Plan. Land at Peg Hi ll, Yate (which is included in the
area identified for the NYNN) is deliverable now and should not be phased to 2016+;
- Even if the build rates suggested by the Council were achievable there is still a
requirement to increase the land available for housing in order to meet housing
needs;
- To meet the need for additional land for housing, settlements outside of the main
towns that have been identified for growth need to be assessed and those capable of
accommodating sustainable development should be recognis ed within the Core
Strategy.
This includes Frampton Cotterell which could accommodate around 400
homes on the “white land” to the south of the village;
- Even after enabling phased sites to be delivered early in the Plan period and
identifying additional capacity in Sustainable Settlement in the Rural Areas, additional
land will be required to meet housing needs, which necessitates a full and
comprehensive green belt review to identify other potential sustainable sites for
development
RECOMMENDATION
-
The plan should set out that the requirement for housing is 33,000 ;
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SOUTH GLOUCESTERSHIRE CORE STRATEGY EIP
Matter 7, Personal ID 3557665
Barton Willmore
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It should identify that land is required for 13,22 4 houses in the years 2011-2016;
-
Barratt Developments are promoting sales with a capacity of 2,900 houses;
-
Land relegated to development in the last years of the plan should be brought forward so
that there are more outlets producing houses in more locations at the same time in the
early part of the plan period;
1.
The plan should propose delivery of new houses as a priority.
Is the overall strategy consistent with sustainable development principles as
contained in the Planning Framework?
Paragraph 7 of the NPPF defines 3 dimensions to sustainable development being: economic,
social and environmental.
Part of the Economic Ro le is to ensure that sufficient land of the
right type is available in the right places and at the right time to support growth and
innovation.
The social role includes a requirement to provide the supply of housing required to meet the
needs of present and future generations.
There is a fundamental flaw in the Core Strategy in that it has not been founded on a
comprehensive and robust evidence base that has properly and objectively assessed the
amount of housing growth required to address housing need and support economi c growth.
We do not object to the level of economic growth forecast through the core Strategy.
However, we do not consider that the proposed strategy for housing growth fulfils the
requirement of the social dimension of sustainable development, in that i t will not provide the
supply of housing required to meet the needs of present and future generations.
As set out within our technical Open House housing toolkit report (Appendix 1 to our paper on
Matter 8), Experian’s latest employment forecast (January 2012 Quarterly Regional Planning
Services) predicts total employment growth over the whole plan period of 22,700 of which
22,200 is forecast between 2011 and 2027.
Of these, it predicts 18,900 Full Time Equivalent
jobs within South Gloucestershire over the period 2006 - 2027, with 18,400 of these between
2011 and 2027.
These figures broadly accord with the level of employment growth expected by the Council of
(21,900 jobs).
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SOUTH GLOUCESTERSHIRE CORE STRATEGY EIP
Matter 7, Personal ID 3557665
Barton Willmore
The arbitrary figure of 21,500 dwellings proposed over the plan period through ear lier versions
of the Core Strategy (as quoted in the Cabinet Papers of 6 th October 2008 which provide the
Council’s response to the RS Proposed Changes) was not based on any technical evidence, that
had not previously been presented to and rejected by the Panel at the RSS EIP and the SoS.
However, the Council has never undertaken an objective assessment of the level of housing
required to meet South Gloucestershire’s needs and achieve the level of economic growth
sought.
Despite this lack of a credible evidence base and despite repeated calls for further evidence
being required to justify the housing growth proposed, the figure was only increased after
Submission and at the request of the Inspector to review this issue. Even when the figure has
been reviewed the Council has failed to assess future housing needs taking account of
predicted economic growth, but instead only sought to justify their supply retrospectively
through an assessment of household growth based on migration trends. This approach fails to
address the economic dimension of sustainable development in the NPPF and fails t o
acknowledge that the proposed level of housing growth will only serve to provide an increase
of 7,386 additional labour force (see Open House Report, Appendix 1 to Matter 8) in the
District, without relying on uns ustainable growth dependent on commuting.
This would result in a significant gap between the level of job growth forecast by the Council
and the additional level of labour force able to be accommodated thro ugh the proposed
housing target, stifling economic growth and exacerbating the existing shortfall and historic
undersupply of housing.
2.
Are there other spatial options which would be more likely to deliver better
outcomes for South Gloucestershire during the pla n period?
Yes, additional sites need to be identified including land at Frampton Cotterill.
The Core Strategy fails to acknowledge the sustainability of any settlements outside of the
urban fringe, Yate and Thornbury.
It divides the plan area into the se areas and the rural
areas, but the Strategy does not establish a settlement hierarchy for the Rural Areas and has
made no attempt to identify suitable and appropriate settlements that could accommodate
expansion without compromising the aims of the Core Strategy, or the green belt.
We will present separate evidence in relation to Matters 8 and 25 which will show that the
overall amount of housing land identified is not sufficient to meet housing needs and that
proposed allocations do not provide a conti nuous 5 years (+20%) supply of land for housing as
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required by the NPPF.
Matter 7, Personal ID 3557665
Barton Willmore
As such, it is imperative that additional land is identified in South
Gloucestershire to meet both short term and longer term housing requirements.
The build rates assumed for the strategic permitted and allocated sites within the Core Strategy
are over optimistic and therefore is a need to deliver additional housing early in the plan period
in order to address the 5 year +20% housing land requirement, required through the NPPF and
also the shortfall in provision which has occurred since 2006 .
We have assessed the likely
delivery rates of the alternative sites within our response on Matter 8 and have shown that
many are over optimistic and undeliverable at these rates. Consequently , we do not consider it
to be feasible to increase build rates further on these sites to the level that would be required
to achieve the 5 year requirement.
The only method of achieving the required level of housi ng throughout the plan period, but
particularly in the early part of the plan period, is to remove the unnecessary phasing of sites
such as Peg Hill, Yate, that are proposed later in the plan period and to allocate additional land
for housing on new sites such as Woodlands Farm, Frampton Cotterill .
In order to ensure suitable and sustainable locations to accommodate the additional growth the
Core Strategy should allocate additional land to other settlements, review the green belt
boundary to establish whether any land adjacent to the conservation area could be proposed
for sustainable development.
Also larger settlements particularly Frampton Cotterill outside of the main urban area should be
assessed for their sustainability and provision should be made within the Core Strategy for
sustainable development to be directed towards these settlements within the rural areas.
3.
Is the overall balance of growth between identified settlements clearly founded
on the evidence base and is it likely to be effective in promoting sustainable
development across the Borough?
No:
The Core Strategy fails to acknowledge settlements within South Gloucestershire other than
Bristol Urban Fringe, Yate, Thornbury and Severnside.
No assessment of the sustainability of other settlements has been undertaken.
There are
opportunities for sustainable growth elsewhere within South Gloucestershire settlements that
have not been identified.
At the Issues and Options Stage (April 2008) the Council sought
views as to how the Core Strategy should accommodate development in the Rural Areas. Such
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SOUTH GLOUCESTERSHIRE CORE STRATEGY EIP
Matter 7, Personal ID 3557665
Barton Willmore
options were not subject to Sustainability Appraisal at that time as they were to be appraised
at Preferred Options Stage.
However this was never undertaken and as such no proper and
fully justified assessment of the capacity and suita bility of the settlements in the Rural Areas
has been undertaken. Only the Preferred Option, which restricts growth within the rural areas
to infil has been subject to Sustainability Appraisal.
As noted in our response to Question 2, the Core Strategy fails to identify sufficient land for
housing and this necessitates the identification of additional land for development.
Frampton Cotterell, is a sustainable location for development. Indeed, Frampton Cotterell has
been recognised as a sustainable loca tion for development by an Inspector in respect of an
Appeal on land south of Heather Avenue in Frampton Cotterill (Appeal Decision attached). The
CS should identify the Woodlands Farm area as an area for growth with capacity for 400
dwellings.
4.
Is the spatial strategy deliverable in the plan period and have the risks to
delivery been properly assessed.
The housing delivery aspects of the Spatial Strategy relies on overly optimistic build rates on a
few key strategic sites that are identified through the Core Strategy. This is discussed further
in our response on Matter 8.
The implication of the high predicted build rates is that
insufficient housing will be delivered over the plan period which will increase prices, reduce
affordability, exacerbate housing needs and stifle economic growth.
All of these impacts
conflict with the objectives of National Planning Policy and of the vision for South
Gloucestershire.
To address this issue, additional housing needs to be identified on new sites to provide more
choice, and capacity to deliver the required level of growth.
5.
Is there sufficient flexibility in the Core Strategy to allow for change or
unforeseen events?
No:
The Core Strategy seeks to limit development to the Urban Fringe; Yate/Chipping Sodbury an d
to Thornbury and ignores Frampton Cotterell, the largest settlement in the rural area close to
the Urban area. Also the Core Strategy unnecessarily delays the delivery of key sites in South
Gloucestershire which exacerbates the problems with housing del ivery and compounds the
shortage in the proposed housing land supply for years to come.
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The Core Strategy should
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SOUTH GLOUCESTERSHIRE CORE STRATEGY EIP
Matter 7, Personal ID 3557665
Barton Willmore
apply reasonable assumptions on build rates to allow sites to come forward over realistic
timescales, but instead it proposes to relegate housing to the latter part of the plan period.
This is also in the context that South Gloucestershire has not delivered their annualised
housing target since 2000/2001 and therefore suffers from a n acute existing under provision of
housing which any potential undersupply in housing delivery over the plan period would
exacerbate.
This is a plan to exacerbate a shortfall in housing rather than to meet housing needs.
The Core Strategy concentrates developments in few locations and assumes unrealistic build
rates. The only way to meet the housing requirements is to ensure flexibility and encourage
housing from more outlets and to bring forward sustainable sites rather than hold them back.
To ensure housing delivery is achievable, sites that are able to be delivered such as Peg Hill,
Yate and Woodlands Farm, Frampton Cotterill, should be allowed to be delivered now and not
unnecessarily delayed for years – which serves no useful purpose. Additional sites should also
be allocated to provide more choice and competition and enable flexibility to respond to market
demand and housing needs, as advocated by the NPPF.
6.
Have the cross boundary implications of the Strategy been taken into account?
No:
Whilst there is an appreciation with the Core Strategy that the deliv ery of some of the sites will
require cross boundary working, and the impacts resulting from the development of proposed
sites e.g. in terms of transport infrastructure has been taken into account, there is no evidence
that a fresh and objective assessment that the implications of the Strategy have been
considered.
The Core Strategy makes reference to the economic growth proposed through the Local
Enterprise Partnership, but makes no reference to how South Gloucestershire will
a) Work with neighbouring Local Authorities to support this level of growth; or
b) Assess and deliver the necessary housing provision required to support this
economic growth.
Specifically, all the Authorities in the West of England (Bristol, B&NES, North Somerset and
South Gloucestershire) agreed to and supported the bid for the LEP of 95,000 new jobs by
2030. Collectively these Authorities are making provision for 69,800 new jobs by 2026, which
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SOUTH GLOUCESTERSHIRE CORE STRATEGY EIP
Matter 7, Personal ID 3557665
Barton Willmore
although lower than the LEP forecast, would generate a requirement for about 109,685
dwellings, based on the economic led Chelmer projections as set out in our Open House Report
(Appendix 1 to Matter 8 statement) of a multiplier of 1.67. The four Core Strategies of Bristol,
North Somerset, B&NES and South Gloucestershire make provision for just 72,200 homes. This
leaves a shortfall of 37,386 homes, most of which centre on the Bristol Travel to work area
(since this area made up the majority of economic potential for the West of England area).
We acknowledge that such a significant shortfall on housing over the West of England area
cannot be met entirely within South Gloucestershire. However, no account has been taken of
the economic impacts of restricting housing growth within South Gloucestershire, particularly
when combined with the shortfall in housing provision of the remaining West of England
Authorities.
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