Dear John and Patrick
Following the withdrawal of the Joint Spatial Plan we are starting again on a new development plan with no preconceived ideas of what the spatial strategy might look like. It is very important for the plan-making process to start with an open mind, understand what the evidence is telling us and respond to the needs of local people. The intention is therefore to consult local communities, businesses, developers and other stakeholders on the challenges the Council is facing in planning for future growth and the choices it has to meet those challenges. This will commence this Summer with a consultation exercise on the Challenges. The feedback from this exercise will help shape the subsequent Choices exercise in the Autumn which will start to consider the options around where development might be best located.
This consultation will tackle many of the issues you highlight such as urban regeneration and renewal, the role of the Green Belt, the need for supporting infrastructure and how we can address the climate emergency and deliver our zero carbon target, including through reducing the need to travel. We will be listening to all the views received from across North Somerset. What is clear however is that development within the Weston urban area alone will not come close to delivering the housing we require and that other options will need to be considered.
The biggest challenge facing North Somerset is how to accommodate the scale of housing which the government requires us to deliver.
Despite a recent Local Plan and a good supply of potential housing sites, the development industry has failed to deliver the scale of new housing which has been planned for. Over the current Core Strategy period the average number of house completions in North Somerset has been 803 per annum (pa) against a target of 1049 pa. This is important, since there are circa 3000 homes for which permission has been granted and developers have not completed. Their desire for profit maximisation is then inflicting additional demand pressures in North Somerset. A way has to be found to make them use those permissions either by financial or legal incentives.
Each year that the developers fail to deliver the housing target, the shortfall is added to the outstanding requirement through the five year supply calculation, making it impossible ever to catch up. The lack of a five year supply in North Somerset means housing appeals such as on the edge of villages are much more likely to succeed.
The government has introduced a standard method for calculating the housing requirement. This currently stands at 1,369 pa for North Somerset, higher than even the 1250 pa the West of England Joint Spatial Plan (JSP) was proposing. This means even more growth for North Somerset.
We believe there is however a flaw with the standard method which is placing an unfair burden on North Somerset. If this was rectified it would change our housing target from one where we are set up to fail to a still very challenging, but more reasonable approach.
The standard methodology is based on household projections. There is a time lag in terms of when updated, new household projections are made available, so the government’s original standard method was based on 2014 data. When the 2016 projections appeared, the government reviewed the methodology but ignored the up-todate evidence and stuck with the 6 years old 2014 data as it boosted overall housing numbers nationally, despite the needs within North Somerset going down. Two years later and the government is currently reviewing the standard method again, and now is the opportunity to use the up to date 2018 data. These new projections demonstrate a continuing declining trend for new housing to meet the needs of North Somerset. We calculate that using current data that the standard method for North Somerset should now be the much lower 1117 pa.
That would make an enormous difference to us. Over a 15 year plan period, instead of 20,535 dwellings, the target would only be 16,755 – meaning we would have to plan for 3780 fewer dwellings. Put it another way, there would be no requirement to deliver a site equivalent to the size of the Mendip Spring proposal.
We are writing to the Secretary of State on this point and would appreciate any support you could give to persuade him that the future housing requirement for North Somerset must be realistic and based on the most up to data.
I totally agree with your objective to maximise the use of urban land particularly through the use of increased densities and this been a North Somerset priority in the existing Local Plan and the JSP. We will continue to explore innovative solutions to maximise potential opportunities where this delivers new high-quality sustainable neighbourhoods supported by the timely delivery of the necessary infrastructure. While maximising delivery within urban areas is essential it is only one component. The evidence provided to support the JSP identified some 1000 new dwellings on sites within the urban areas of North Somerset (over and above existing commitments) and primarily in Weston. Even if that number could be increased and shown to be deliverable (along with the cost of supporting infrastructure), the scale of the housing requirement means that the vast majority of the growth will need to be accommodated elsewhere on greenfield sites. We also need to consider the changes wrought by the Covid-19 pandemic. There is developing evidence that people now wish to leave larger cities and live in less densely populated areas such as villages and small towns, since they can now work more easily from home.
While the M5 is an important artery running through North Somerset, the Council has declared a climate emergency and is keen to explore options which seek to reduce car dependency, particularly as we adjust to new patterns of working and travelling postCovid 19. Many of your comments seem to encourage solutions which would increase car use which is perhaps surprising given your opening comments about the failures of the garden village approach. Should we not be encouraging greener transport solutions? The M5 is of course managed by Highways England, not the Council, and we will continue to have discussion with them relating to the issues you raise.
Roughly 40% of North Somerset is currently Green Belt. Your proposal to extend it southwards would effectively mean that in the future the whole of the district would be either Green Belt, AONB or floodplain. At the moment the enormous challenge of delivering the government’s housing target is placing massive pressure on the existing Green Belt. Given our situation I cannot foresee any circumstances where a government inspector would sanction an extension of the Green Belt in the way you describe.
What we would like to facilitate through you is a conversation with government to rebalance the planning system away from one which is currently stacked in favour of the development industry to one which listens to our communities.
Yours sincerely
Cllr James Tonkin
Executive Member Planning & Transport
North Somerset Council