Land at Court House Farm, Plummers Hill, Easton-In-Gordano, Bristol, BS20 0PS

www.pegasusgroup.co.uk

Representations to the North Somerset Issues and Options Consultation

Land at Court House Farm, Plummers Hill, Easton-in-Gordano, Bristol, BS20 0PS

FOR DATE JOB CODE Lands Improvement December 2018 P16-1434

DECEMBER 2018 | AB | P16-1434

REPRESENTATIONS TO THE NORTH SOMERSET ISSUES AND OPTIONS CONSULTATION

LAND AT COURT HOUSE FARM, PLUMMERS HILL, EASTON-IN-GORDANO, BRISTOL, BS20 0PS

ON BEHALF OF LANDS IMPROVEMENT

Prepared by: Alex Bullock

Pegasus Group

©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

CONTENTS:

Page No:

1. INTRODUCTION 1 2. SUSTAINABILITY APPRAISAL 2 3. APPROACH TO NORTH SOMERSET SETTLEMENTS 3 4. LOCAL HOUSING GROWTH 8 5. SETTLEMENT HIERARCHY 11 6. SETTLEMENT BOUNDARY REVIEW 12 7. GARDEN VILLAGES AND NEW COMMUNITIES 13 8. URBAN LIVING 14 9. BRISTOL AIRPORT 15 10. LAND AT COURT HOUSE FARM, EASTON-IN-GORDANO 16

APPENDICES:

APPENDIX 1: SITE LOCATION PLAN

Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

1. INTRODUCTION

1.1 Pegasus Group write on behalf of our client Lands Improvement (hereafter referred to as LI) who own land at Court House Farm, Plummers Hill, Easton- in-Gordano (the site). A Site Location Plan showing the extent of the land interest is appended to this representation.

APPENDIX 1: SITE LOCATION PLAN

1.2 The site has been previously promoted by Pegasus Group as part of the West of England Joint Spatial Plan (JSP) and the North Somerset Site Allocations Plan (SAP).

1.3 The Site is owned by LI and is located on the western edge of Easton-in- Gordano. We consider that Easton-in-Gordano should accommodate a proportionate level of growth commensurate with its role and function. There is a particularly well defined affordable housing need associated with the settlement.

1.4 For this local need to be realised a positive approach to site identification will be required. We consider that Easton-in-Gordano and land at Court House Farm to be suitable locations for a non-strategic housing allocation.

1.5 These representations set out the site’s spatial context, responds to the questions raised in the Issues and Options document (September 2018) and the supporting draft Sustainability Appraisal.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

2. SUSTAINABILITY APPRAISAL North Somerset Wide Issues (Page 5)

2.1 In formulating our response to the Issues and Options consultation we have reviewed and considered the contents of the Sustainability Appraisal (SA) Scoping Report (September 2018).

2.2 We note and welcome the issues identified by the Council as set out within Section 2 of the SA recognising the importance of ‘meeting communities needs for housing, including affordable housing’ and ‘pressure on the countryside/greenfield and Green Belt sites from planned development’.

2.3 Table 10 identifies that significant housing growth is required over the plan period. It goes on to highlight the need for the Local Plan to secure the delivery of housing in the right places and expresses an understanding that there will be a need to look sequentially at greenfield opportunities, given that opportunities for brownfield sites to contribute are somewhat limited.

2.4 It is however disappointing that the Green Belt does not feature within the Sustainability Appraisal Framework Objectives as set out within Table 11. This is somewhat surprising given both the scale of the Green Belt within North Somerset (which covers about 40% of land in North Somerset), the commentary within the wider Issues and Options document and the importance of it to housing delivery within the District. We consider the Objectives should be amended accordingly and suggest the following wording to be inserted to Section 5 Objectives listed on page 50 of the Sustainability Appraisal:

“Minimise the impact on the Green Belt but where appropriate consider potential revisions to Green Belt boundaries.”

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

3. APPROACH TO NORTH SOMERSET SETTLEMENTS

Weston-super-Mare (Page 9)

3.1 We are broadly supportive of the proposed approach to development at Weston-super-Mare. We consider that there are ample opportunities for urban intensification and regeneration within the settlement which will ensure the settlement can meet its needs. Given that is the case then there should be no need for greenfield allocations at Weston-super-Mare.

Clevedon (Page 11)

3.2 With regards to Clevedon, we support a small level of growth, albeit this would need to be considered alongside the likelihood of the JSP contingency site to the east of the town coming forward.

3.3 This is a factor that might limit the quantum of development allocated at Clevedon. Indeed, we consider it highly likely that the Council will need to utilise this contingency site due to the likely deliverability issues associated with the other SDLs identified within the JSP.

3.4 However, the sustainability of Clevedon means that it should be the focus for at least some development over the plan period. As such, we support the principle of small scale Green Belt releases around the town, following a detailed Green Belt review.

Nailsea and Backwell (page 12)

3.5 The Council’s primary concern at Nailsea and Backwell appears to relate to the way in which the SDL will take shape. We are broadly supportive of an SDL being identified and consider it appropriate location given the scale and role of Nailsea.

3.6 We would suggest that the requirement to deliver a strategic level of growth, the existing commitments set out in the development plan and the constrained nature of both settlements (namely in Green Belt and ecological terms), means that there is limited scope for additional sites to be identified in this location.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

Portishead (Page 13)

3.7 As with Weston-super-Mare, we believe that there is scope to deliver additional housing at Portishead on previously developed sites rather than on greenfield sites around the town. However, we would support small scale Green Belt releases to accommodate some development where the Green Belt is considered to make only a limited contribution to the purposes of its original designation and sustainably located.

3.8 We also strongly support the re-opening of the train station at Portishead as this would significantly improve the sustainability credentials of the town more generally, but also facilitate the re-opening of other stations on the line to Bristol, namely at Pill/Easton-in-Gordano.

Green Belt (Page 14)

3.9 As stated previously, we are supportive of the identification of appropriate Green Belt releases in certain locations within the Borough. This is largely because there are several sustainable locations in the Green Belt in North Somerset.

3.10 We would not, however, expect to see Green Belt land released without a detailed green belt review being undertaken. Whilst we note that some of this work was undertaken as part of the JSP process, some areas were not addressed in as great a level of detail. We would expect a detailed assessment to take place for all potential sites.

3.11 We would, naturally, support the release of Green Belt which makes a limited contribution to meeting its five purposes. We acknowledge the example provided within the consultation document where the creation of the New South Bristol Link Road has severely reduced the contribution that land contained by it now makes to the Green Belt. We consider that there are similarities with Easton-in-Gordano and its relationship with the M5 and Junction 19.

3.12 There are similar opportunities to release poorly performing parts of the Green Belt in sustainable locations to further meet the residual housing requirement left over from the JSP, especially where there is a demonstrable need to do so.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

3.13 In the case of Easton-in-Gordano/Pill, the Green Belt boundary directly abuts the settlement boundary and, as a result, there are limited opportunities within the defined boundary (and outside the Green Belt) for new housing proposals to be brought forward.

3.14 We are aware that the Pill & District Community Land Trust was formed in 2016 to give the community a greater level of control over the types of houses to be built within the three parishes (Abbots Leigh, Easton-in-Gordano and Pill). A survey undertaken in November 2016 identified a significant affordable housing need:

• 29 affordable rented homes (2 of which are needed for elderly persons);

• 10 households which need intermediate property (shared ownership); and

• Potential need from 13 further households (not assigned to a category).

3.15 It is unlikely that sites of a sufficient scale to meet this affordable housing need can be found within the defined settlement boundary and in the case of Easton-in-Gordano there are limited brownfield opportunities. As a result, and in consideration of the existing Policy ‘DM12: Development within the Green Belt’, many sites are unlikely to be found acceptable to the Council under this context.

3.16 If there is a commitment to meeting the community’s needs, as set out within the SA Scoping Report, then a solution is needed to this policy conflict. We would suggest that there is merit for the Council to release sustainable parcels of Green Belt land where it makes only a limited contribution in accordance with the Councils suggestion on page 15.

3.17 This would be consistent with the suggested approach around Bristol Airport and the South Bristol Link Road and in order to help inform local communities about locations which may be suitable for release to help address the housing needs (including affordable).

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

3.18 We believe it likely that there will be a number of communities across North Somerset, in sustainable locations, which need to bring forward sites for residential development in order to address the significant housing needs of their community but have been unable to do so due to constraints such as these.

Central Parishes (page 16)

3.19 As with Nailsea and Backwell, the focus of the Council on the Central Parishes, relates to the delivery of the proposed Garden Villages at Banwell and Churchill.

3.20 The Council have identified a number of issues associated with the delivery of strategic growth in this location which highlight why we have reservations over the ability of the SDLs to deliver what they are scheduled to, over the plan period.

3.21 Unlike the SDL at Nailsea, the Garden Villages are located in rural locations and adjacent to smaller settlements.

3.22 We are concerned by the significant reliance on the strategic development locations at Banwell and Churchill given the overall cost of delivering the associated transport programme.

3.23 The Transport Topic Paper 8 (WED007) indicates that the total cost to deliver the transport works for the SDL’s is estimated to be between £1-1.4 billion and this would be “an ambitious programme and would represent a step- change in the level of investment from that achieved in the last two decades”. For the Banwell and Churchill components this is estimated as being between £180-185million.

3.24 As the Topic paper makes clear “in most cases, it is anticipated that the transport schemes will be completed either in advance of or during the early phases of housing build-outs in the relevant SDL’s”. Such a conclusion is not surprising given the standard of existing infrastructure and its ability to accommodate major strategic growth.

3.25 Whilst, we do not object to the Councils pursuing ambitious programmes of work we remain sceptical that all works will receive funding (and it is

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

understood none benefit from committed funding at present) and even if they are funded the associated timescales are likely to be significantly longer and therefore implementation and build outs will be significantly longer than currently envisaged and by consequence delivery of residential units will be over a much longer time horizon than currently anticipated i.e. all units complete by 2036 (except 125 dwellings).

3.26 It is our position that the Council should reduce its dependency on infrastructure heavy strategic development locations within this plan period.

3.27 We consider that the proportion for non-strategic development locations should increase to provide a more balanced approach.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

4. LOCAL HOUSING GROWTH

4.1 We note that, as currently drafted, the Issues and Options document seeks to take forward the figures which are set out within the emerging West of England Joint Spatial Strategy (JSP). Examination hearings are scheduled for May 2019 and one of the early sessions will be around the overall housing requirement for the region before moving on to consider some of the identified Strategic Development Locations (SDLs).

4.2 We consider it likely that there will be changes to both for the following reasons:

• the overall housing requirement is too low and does not take full account of the affordable housing need for the region; and

• several of the strategic development locations are not deliverable without significant funding for infrastructure (see our comments within paragraphs 3.21-3.26 above).

4.3 In the case of the housing requirement the current IOP is predicated on the submission version of the JSP which identifies a need for 102,200 new homes across the Plan area and the expectation that North Somerset will deliver some 25,000 homes. Of which only 1,000 dwellings have been allocated to non-strategic growth.

4.4 As we and many others (including the Home Builders Federation) have suggested this overall requirement for the JSP area and that attributed to North Somerset is too low. This under estimation can be attributed to three inter related issues:

• Addressing housing affordability;

• Low economic growth assumptions; and

• Lack of adjustment to meet significant affordable housing needs.

4.5 Although the JSP is being examined against the requirements of the National Planning Policy Framework (NPPF, 2012), the new standardised methodology for calculation of local housing need based on household projections and housing affordability makes for interesting comparison. It is of note that the

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

standard method achieves only a minimum housing need figure and further uplifts may be considered necessary.

4.6 The standard method results in the following outcomes:

Authority 1 Year Requirement 20 Year (dwellings) Requirement (dwellings) Bath & North East Somerset 657 13,138 Bristol 2,440 48,802 North Somerset 1,338 26,760 South Gloucestershire 1,402 28,030 West of England Total 5,836 116,730 Table 1 – West of England Summary Standard Method Requirements

4.7 By consequence if the JSP’s figures are too low and North Somerset’s apportionment then any North Somerset Plan will be seeking to deliver numbers which are not accurate.

4.8 As a result, it is our opinion that there will be a need to deliver in excess of the 1,000-dwelling non-strategic growth currently identified for North Somerset over the plan period. We agree that this level of growth should be steered to the most sustainable settlements within the District but acknowledge that the current Issues and Options document does not indicate where the Council intends to meet these needs.

4.9 It is understood that the Council will seek to identify potential sites, using the SHLAA, as part of its preferred option document. Whilst we agree that this would be a suitable point at which to identify specific sites, we question whether the Council will have an appropriate evidence base to reach such a conclusion given our commentary in relation to the Green Belt as discussed above.

4.10 The conclusions drawn as part of the SHLAA exercise to date focus on the existing policy framework and, as a result, sites within the Green Belt, for example, are unlikely to score positively. We would therefore suggest that the Council needs to undertake a detailed review of the Green Belt now so that opportunities are not being lost simply because out of date evidence is informing local plan decision making. We note that a number of the Strategic Development Locations are currently within the Green Belt but will be

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

removed as part of the future Local Plan adoption process. We would suggest that a similar approach could also be taken for the non-strategic element.

4.11 A more detailed review of the Green Belt will also help communities producing neighbourhood plans to be able to make allocations to address community needs, particularly those that cannot be met within the existing settlement boundary and are otherwise constrained by the Green Belt designation.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

5. SETTLEMENT HIERARCHY Settlement Hierarchy Review (Page 20)

5.1 The consultation document highlights the need to review the settlement hierarchy by needing to address the new housing requirement as set by the JSP (not yet fixed). The Consultation document proposes three options:

• Option 1 – Keep the existing hierarchy but re-assess the position of each settlement within the hierarchy.

• Option 2 – An expanded hierarchy with an additional tier between Service and Infill Villages.

• Option 3 – Growth based strategy. Group together settlements with capacity for housing sites with a tightly worded criteria-based policy to guide where development will go.

5.2 We would favour Option 1 to retain the existing settlement hierarchy as it is our belief that this current arrangement is the most suitable.

5.3 However, we would suggest it is not simply considering where within the hierarchy a settlement should sit, but also what levels of development are acceptable at such locations. We note that in the case of Service Villages a permissible approach to small scale development, of approximately 25 dwellings is allowed beyond settlement boundaries. However, this would not be available to those settlements whose boundary is constrained by the Green Belt. As a result, those villages have more limited options for growth, despite needing to grow in order to meet the community’s needs, in particular affordable housing which will be delivered by allowing an appropriate level of market housing.

5.4 We would suggest that any review of the hierarchy needs to be undertaken in association with a detailed review of planning constraints so as to ensure all communities have the ability to grow either through a permissible policy approach or by way of specific site allocations.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

6. SETTLEMENT BOUNDARY REVIEW Boundary Reviews (Page 26)

6.1 The Issues and Options document proposes two options for the consideration of potential amendments to the settlement boundaries policies.

• Option 1 – Adjust settlement boundaries to include new allocations within the boundaries and retain the current policy which allows sites to come forward adjacent to boundary.

• Option 2 – Adjust settlement boundaries to include new allocations within the boundaries but remove the current policy which allows sites to come forward adjacent to the boundary.

6.2 We would favour Option 1; however, in relation to settlements such as Easton-in-Gordano sites beyond the settlement boundary are only likely to be brought forward via specific allocations given the Green Belt constraint.

6.3 We would also stress that the approach to settlement boundaries cannot be considered in isolation from other aspects of Local Plan policy. This needs to consider existing constraints based on up to date evidence as well as a detailed understanding of both the overall requirement (as evidenced by the JSP) but also the aspiration of local communities to meet their specific needs.

6.4 As is evident from the consultation document there is a mixture of approaches to settlements within North Somerset which are constrained by the Green Belt. Some are washed over whilst others are inset from it. Whilst a consistent approach may be favoured moving forwards, it must be underpinned by a robust evidence base in order to inform choices regarding both site allocation and the identification of suitable and defensible boundaries associated with any Green Belt release.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

7. GARDEN VILLAGES AND NEW COMMUNITIES

7.1 Our broader view, and in line with our comments above, is that there remain serious question marks over their ability to deliver the proposed quantum of housing over the current plan period at several the SDL’s particularly those within North Somerset (e.g. Banwell and Churchill).

7.2 The Garden Villages and Communities identified are very large allocations and at this stage only very limited detail has been provided by the JSP as to what exact land parcels these sites consist of (only high-level detail is provided within the Development Locations Template document). It is reasonable to assume that given the size of these opportunities will suffer from fragmented land ownership which will slow the speed of delivery assuming that most owners are willing to bring land forward.

7.3 A further concern is the significant up-front infrastructure costs (estimated at more than £1 billion) and long lead in times associated with strategic development on this scale. Such infrastructure is likely to be needed early on to enable delivery and until this is in place delivery will be slow.

7.4 Although much smaller in scale, the build out of the Weston Villages Strategic site has been slower than anticipated, partly due to infrastructure delivery

7.5 As such, the new garden villages will need to be coupled with a flexible and sensible approach to development on smaller, non-strategic sites that can be delivered in the shorter term.

7.6 We consider a greater emphasis should be placed on non-strategic opportunities instead of the over reliance on large complex new settlements. As a result, a great proportion of units would be delivered earlier in the Plan period. Such an approach would be consistent with the ethos behind the Housing Delivery Test which requires consistent housing delivery over a three- year period.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

8. URBAN LIVING

Urban Living Opportunities (Page 62)

8.1 The Council’s Urban Living strategy is focussed on maximising densities in all locations, alongside a more specific approach to delivering higher densities at Weston-super-Mare.

8.2 We are generally supportive of any approach that seeks to maximise the efficient use of land in sustainable locations. We would, however, be mindful of any approach which seeks to establish minimum densities for individual towns or as part of a site allocations process due to the fact that unforeseen technical issues might not mean this is possible. Flexibility would need to be built into any proposed policies to allow for lower densities to be achieved on sites where there are clear reasons for doing so.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

9. BRISTOL AIRPORT Bristol Airport (Page 74)

9.1 We support proposals to expand Bristol Airport and feel that the Council should plan positively to facilitate them. In order to provide certainty and avoid undue delays, we consider it appropriate to remove land from the Green Belt that would be safeguarded for its future expansion.

9.2 We consider that such an approach should be carried forward within other areas of North Somerset where the Green Belt makes only a limited contribution and where those locations are sustainably located.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

10. LAND AT COURT HOUSE FARM, EASTON-IN-GORDANO

10.1 The site (as identified at Appendix 1) is located on the western edge of the settlement of Easton-in-Gordano. The M5 runs along the northern edge of the site and the site is located in close proximity to Junction 19 with the remainder of the northern boundary abutting Gordano services.

10.2 The site is located beyond the defined settlement boundary and is located within the Green Belt. Although located within the Green Belt the JSP Green Belt Stage 2 Assessment concluded that the cell 77a (which includes the Court House Farm site) made:

• Limited Contribution – Checking the unrestricted sprawl;

• Limited Contribution – Preventing neighbouring towns merging into one another;

• Limited Contribution – Assisting in safeguarding the countryside from encroachment;

• No Contribution – Preserving the setting and character of historic towns; and

• Limited Contribution – Assisting in urban regeneration, by encouraging the recycling of derelict and other urban land.

10.3 The construction of the M5 motorway and the built-up area of Pill has created a more defensible boundary close to the urban area resulting in a small pocket of land which no longer performs an important Green Belt function.

10.4 The site is located within Flood Zone 1 (area of lowest risk) and has no overriding constraints to development.

10.5 Although a small number of Grade II Listed Buildings are located close to the site’s boundary, they are not considered to restrict the development of this site.

10.6 The site benefits from two access points with the principal access being onto St. George’s Hill. The site is near the Avon Cycleway which runs along the front of the site and near a bus stop which serves Bristol (via the X3A and X4 services) twice hourly.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

10.7 The existing evidence suggests that this site is highly suited to residential development and it is located on the edge of a sustainable settlement. The sustainability credentials of Easton-in-Gordano would be further enhanced if the train station at Portishead is delivered.

10.8 Given that the site only makes a limited contribution to the functions of the Green Belt we consider this site is highly suited for release and allocation and assist with the very challenging housing numbers to be delivered over the plan period.

10.9 The Site can accommodate approximately 200 dwellings and provide the identified affordable housing need as noted in section 3 of this report.

10.10 We would welcome the opportunity to discuss the site further with North Somerset Council during the new Local Plan progressions.

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Lands Improvement Land at Court House Farm, Easton-in-Gordano North Somerset Council Local Plan: Issues & Options Representations

APPENDIX 1

SITE LOCATION PLAN

DECEMBER 2018 | AB | P16-1434

P16-1434 - Easton-in-Gordano

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