representations to the north on behalf of brunelcare and

REPRESENTATIONS TO THE NORTH SOMERSET CONSULTATION DRAFT

SITES AND POLICIES DPD

ON BEHALF OF BRUNELCARE AND ST PETER’S HOSPICE

Pegasus Planning Group First Floor, South Wing Equinox North, Great Park Road Almondsbury Bristol BS32 4QL Telephone: 01454 625 945 Facsimile: 01454 618 074 PPG Ref: BRS.4066 Date: April 2013 COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Ltd

REPRESENTATIONS TO THE CONSULTATION DRAFT SITES AND POLICIES DPD ON BEHALF OF BRUNELCARE AND ST PETER’S HOSPICE

CONTENTS:

Page No:

1. INTRODUCTION 1

2. POLICY NA2 NORTH-WEST NAILSEA 3

3. POLICY NA3 TRENDLEWOOD WAY, NAILSEA 5

4. CONCLUSION 8

APPENDICES 1. TRENDLEWOOD WAY SITE LOCATION PLAN


HBR/BRS.4066 April 2013 1

1. INTRODUCTION

1.1 Pegasus Planning Group is instructed by Brunelcare and St Peter’s Hospice to

comment on the consultation draft of the sites and Policies DPD of North Somerset

Council.

1.2 Land at Trendlewood Way Nailsea is owned by Brunelcare and St Peter’s Hospice

and is available for residential development within the settlement boundary (see site

location plan attached at Appendix 1). The site has historically been allocated by

Policy CF/4 of the North Somerset Local Plan (2007) for an ‘unspecified community

use’ but has never come forward as such.

1.3 The Core Strategy (April 2012) identifies Nailsea as one of three towns (along with

Portishead and Clevedon) which will accommodate most development outside of

Weston.

1.4 Both Policy CS14 and CS31 which set out the housing target and policy approach to

development within Nailsea have been revoked as a result of the recent legal

challenge to the Core Strategy. A housing target for North Somerset and Nailsea

therefore does not exist.

1.5 During the course of the Core Strategy examination it became apparent that the

declining population of Nailsea and its age profile called for greater levels of

development.

1.6 A total of 210 dwellings were proposed for Nailsea by Policy CS14 of the Core

Strategy, a majority of which are already completed or committed. Importantly

however, the Core Strategy Inspectors Report notes that these are minimum figures

and need not be seen as restricting development that is justified.

1.7 Policy CS31 stated that residential development within the settlement boundary of

Nailsea would be acceptable in principle, provided it reflects the character of the local

environment and doesn’t cause any adverse impacts.

1.8 In addition to the 210 dwellings proposed at Nailsea, proposals for mixed use

schemes adjacent to the settlement boundary to meet local needs were supported

provided that it is not in the Green Belt, is supported by the local community and

identified in the Sites and Policies DPD.



1.9 Despite there being no adopted policy framework for development in Nailsea it is

clear therefore that residential development of a scale greater than 210 is called for

to 2026.

1.10 Without a clear and objective assessment of housing need within Nailsea, Core

Strategy Policy CS14 as proposed could never actually meet need in Nailsea, as

required by the NPPF.

1.11 The revocation of this policy provides an opportunity to properly address this issue

and set an adequate housing target to meet need in Nailsea.

1.12 Working to this target the Sites and Policies DPD should then be able to assess all

available sites in and around Nailsea on their merits and allocate an appropriate site

or sites to meet the target.



2. POLICY NA2 North-West Nailsea

2.1 This policy claims to respond to the additional (unspecified) need identified in the

Core Strategy for a sustainable mixed use development adjacent to the settlement

boundary of Nailsea.

2.2 Whilst the supporting evidence base paper for Nailsea identifies a need for additional

housing in Nailsea it does not quantify this need. In order to plan sustainably for

Nailsea, an overall estimation of the scale of new housing required in the town is

required.

2.3 In addition, the evidence base paper makes no attempt to consider sites that may be

available to deliver the additional housing and the preference in Policy NA2 for land

to the north-west of Nailsea is therefore not evidenced and unjustified.

2.4 The fact that the site was previously allocated in the Clevedon, Nailsea and

Portishead Local Plan (1992) is not justification for choosing land to the north-west of

Nailsea over other potential other sites. Nor is it justification for setting a capacity for

450 dwellings when no objective assessment of need in Nailsea has been

completed.

2.5 Furthermore, revoked Core Strategy Policy CS31, upon which Policy NA2 hinges,

requires that any proposal for development adjacent to the settlement boundary of

Nailsea be supported by the local community. This is not equivalent to the Town

Council’s support.

2.6 There appears to have been no public consultation on the scale and location of new

development required adjacent to Nailsea, let alone any consultation on the particular

land in question. A Neighbourhood Plan for Nailsea is not being prepared and the

Core Strategy proposed no significant development at Nailsea. The Town Council

cannot therefore be said to represent the local community’s views on this matter.

2.7 In any case, it is already clear from the Town Council representations to the Core

Strategy that land to the north-west is not their preferred site. In fact land to the north-

west of Nailsea was previously described by the Town Council as one of the most

unsustainable locations for development.

2.8 It is not clear therefore how the Council believe that ‘local support’ for this proposed

allocation has been demonstrated. Presumably, should the residents of Nailsea



object to the allocation through the Sites and Allocations DPD consultation then

Policy CS31 cannot said to be met and the proposed allocation should be removed

on this basis.

2.9 Furthermore, the achievability of housing on land to the north west of Nailsea is not

confirmed. The site is known to suffer from a significant number of constraints

including:

- Parts of the sites north west boundary are within Flood Zones 2 and 3, the

extent of which according to the Strategic Flood Risk Assessment could

increase as a result of climate change;

- Potential for land contamination due to adjoining playing field which was

formerly a sewage treatment works;

- The site is adjacent to an SSSI and wildlife site to the north;

- Pylons and overhead electricity lines cross the site;

- An archaeological desktop study undertaken by Avon Archaeological Unit in

1994 found evidence which suggested there may be remains of later medieval

field systems and a possible early post-medieval farmstead.

2.10 The likelihood of this site coming forward within the next 5 years or even being

suitable for the level of residential development indicated is by no means certain and

should not therefore be relied upon.

2.11 By contrast land at Trendlewood Way is within the settlement boundary,

unconstrained and capable of delivering up to 40 dwellings within the next five years

to meet housing demand and help to address the Town Councils concerns in a truly

sustainable location.



3. Policy NA3 Trendlewood Way, Nailsea

3.1 Policy NA3 is concerned with land at Trendlewood Way Nailsea. This area of land

has historically been allocated for community uses but has failed to ever come

forward as such.

3.2 The Sites and Policies DPD, proposes to re-allocate the site for a mix of uses, still

including a significant proportion of community uses.

3.3 Led by the aspirations of Nailsea Town Council, Policy NA3 proposes the following

uses for the land:

- At least 0.7 ha for community uses, to include 0.5ha allotments and 0.2 ha for

another community use such as a church and car park;

- Retention and management of the woodland adjoining the site to the north west;

- Provision of retirement homes on the remainder of the site (approximately 14

dwellings; and

- Protection of living conditions of existing residents and future occupants.

3.4 No evidence of the need for such uses or the suitability and viability of this particular

site for them is put forward by the Council. In this way the policy cannot be

considered deliverable and therefore is ineffective.

3.5 The fact that the site has been allocated for community facilities for over a decade

and never come forward as such indicates that there is no demand for such

development within this area of Nailsea. The proposed allocation by the Sites and

Policies DPD will only continue this position and the site will continue to make no

positive contribution to the community of Nailsea.

3.6 The provision of 14 retirement dwellings will not provide enough return to enable the

landowner and developer to deliver the proposed level of on-site community facilities.

The proposed allocation is therefore contrary to paragraph 173 of the NPPF which

states that:

“The sites and scale of development identified in the plan should not be subject to

such a scale of obligations and policy burdens that their ability to be developed viably

is threatened. To ensure viability, the costs of any requirements likely to be applied to

development ...should when taking account of the normal cost of development and



mitigation, provide competitive returns to a willing land owner and willing developer to

enable the development to be deliverable”

3.7 Furthermore, the types of community uses proposed are also considered

inappropriate in this location.

Church

3.8 There is no evidence of demand for a new church within Nailsea. For example,

neither the Parish Plan undertaken in 2008 nor the Parish Plan or Policy Statements

identify the need for a new church.

3.9 The 2011 Census shows an increase in the number of Nailsea residents who state

that they have no religion from 16% in 2001 to 27% in 2011. At the same time the

number of residents who state their religion as Christianity has declined by 13%.

3.10 There are already seven churches in Nailsea including St Francis Church which is

located within walking distance of land at Trendlewood Way.

3.11 Furthermore, there is no evidence of funding to buy the land and deliver such

development, nor a willing operator.

3.12 Based on all of the above, the proposal within Policy NA3 for a church and car park is

not justified and not effective. The policy cannot therefore be considered ‘sound’.

Allotments

3.13 As confirmed by proposed Policy DM 56 which permits new development associated

with local food production in the countryside, allotments are considered acceptable

development outside of the settlement boundary.

3.14 Land at Trendlewood Way is a site within the existing settlement boundary which

provides a unique opportunity to deliver truly sustainable housing in line with the

objectives of the adopted Core Strategy and within the next 5 years. Development of

the site for housing with a financial contribution to the provision of off-site allotments

would therefore represent a more appropriate form of development in this location.

3.15 Given the apparent importance of Allotments to the Town Council it is unjustified that

no allotments are sought on the large mixed use allocation at land north west of



Nailsea. This scheme will generate a significant number of new dwellings and

therefore create increased demand for allotments.

Retirement Housing

3.16 The restriction of the development to only retirement housing is also unjustified and

does not make the most effective use of the land.

3.17 Land at Trendlewood Way is within walking distance of both Nailsea Secondary

School and St Francis Primary School. It therefore provides a highly sustainable

location for the provision of family housing (as desired by the Town Council to

prevent school closures).

3.18 Furthermore, proposed Development Management Policy 40 which relates

specifically to the provision of retirement accommodation states that ‘shops, public

transport, community services and medical services’ should be easily accessible by

residents with limited mobility and no access to a car. On the basis of this policy, land

at Trendlewood Way is not therefore the most appropriate location for retirement

accommodation.

3.19 All community services and medical services which would be required by elderly

people are located along the High Street of Nailsea around 1 mile from land at

Trendlewood Way – this exceeds walking distance for people with limited mobility.

3.20 The proposed development of 450 dwellings at North West Nailsea will by virtue of

proposed Development Management Policy 40 (it exceeds 100 dwellings) will be

required to provide a proportion of retirement accommodation and it is considered

that this location is far more appropriate in terms of distance form community and

medical services for such accommodation.



4. CONCLUSION

4.1 As demonstrated by the information provided above, in their current state, Policies

NA2 and NA3 of the Consultation Draft Sites and Policies DPD are unsound.

4.2 Policy NA2 proposes to allocate a large mixed-use development on an area of land

without any evidence that:

- The level of housing proposed is justified. The Core Strategy identified a target of

210 dwellings for Nailsea and potential for mixed use development adjacent to

the settlement boundary where it would meet identified local needs. No work has

been undertaken to quantify local housing needs in Nailsea, therefore the

proposed level of development at North-West Nailsea cannot demonstrate that it

meets this criteria.

- This site is the most appropriate. No supporting technical evidence is provided to

demonstrate that the entire settlement boundary of Nailsea has been evaluated

and that this location represents the most sustainable location for an alteration. It

is not therefore demonstrated that land to the north-west of Nailsea is the most

appropriate strategy when considered against reasonable alternatives.

- Land to the north-west can actually be delivered within the plan period. This is

particularly pertinent given the sites history. Despite allocation in a previous plan

and a planning application the site has not come forward and is known to suffer

from a number of constraints. The policy is not therefore shown to be deliverable

over the plan period and is not therefore effective.

4.3 Policy NA3 proposes to allocate land at Trendlewood Way for a mix of community

facilities and retirement housing without any evidence of:

- Demand for any community facilities within this area. The site has been allocated

for community uses for over a decade. It is clear that there is no identified

demand for a specific community facility as the policy broadly refers to

“community uses such as a church and car parking”. There is certainly no

evidence of demand for a new church in Nailsea, particularly in this area. The

policy is therefore unviable, unjustified and ineffective.

- The need to locate allotments in this particular location. Whilst it is accepted that

it would be desirable to provide additional allotments in Nailsea, there is no



justification for them in this location. Policy DM56 of the same document allows

allotments outside of the settlement boundary, therefore a number of other

suitable locations exist for the provision of allotments. Land at Trendlewood Way

is one of the only suitable sites for residential development within the settlement

boundary and within the next five years. Such development is required to fund

the delivery of allotments in Nailsea.

- The suitability of this location for retirement homes. Land at Trendlewood Way is

not located within walking distance of the town centre for people with mobility

problems. In line with Policy DM40 of the same document it would not therefore

represent an appropriate location for older peoples housing.

4.4 Land at Trendlewood Way is one of only three sites within the settlement boundary

which were identified by the Council’s SHLAA as having potential for the delivery of

market housing within the next five years.

4.5 In light of the Council’s acceptance of a need for more family housing in Nailsea and

the current lack of a housing target and therefore five year supply across North

Somerset, land at Trendlewood Way is an opportunity to help address these two

issues. The proposed allocation of the land for retirement homes, allotments and an

unidentified community use is not justified and is an ineffective use of a highly

sustainable piece of land within the settlement boundary and within walking distance

of local schools.

4.6 There is no demand for a community use in this area and no offers from operators of

such uses to buy the land and fund development of such. The same is true of

allotments.

4.7 The proximity of the site from the town centre makes it an inappropriate location for

retirement housing. Retirement housing, community facilities and allotments will in

any case need to be provided by any large scale mixed use allocation adjacent to the

settlement boundary.

4.8 As proposed, Policy NA3 will only prevent land at Trendlewood Way from coming

forward and making a positive contribution to the local community.



4.9 Allocating land at Trendlewood Way for 100% open market housing is therefore a

more appropriate and effective use of this land. Such an allocation would still deliver

off-site financial contributions to community uses and allotments as appropriate.

APPENDICES

REPRESENTATIONS TO THE DRAFT CONSULTATION SITES AND POLICIES DPD

BRS.4066 April 2013

APPENDIX 1

TRENDLEWOOD WAY SITE LOCATION PLAN

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representations to the north on behalf of brunelcare and

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