Core Strategy - Consultation Draft

Comment ID 3331265/CSCD/2
Document Section Core Strategy - Consultation Draft Chapter 1: Introduction Relationship to the Regional Spatial Strategy View all on this section
Respondent Deleted User View all by this respondent
Response Date 25 Feb 2010
Comment
Paragraph 1.5 confirms that, "Legislation requires that the Core Strategy must be consistent with national and regional policy. Within the South West the emerging Regional Spatial Strategy (2006-2026) provides the regional context, with the Secretary of State's Proposed Changes published in July 2008. There is no date for the final approval of the RSS, this council has objected to key elements of the document (particularly the proposed Green Belt urban extension at SW Bristol), and it is anticipated that there may be changes to regional guidance introduced following the general election early next year".
The approach taken within the Core Strategy with regard to the Bristol South West Urban Extension is to not proceed with the formulation of a policy framework to ensure timely delivery of the SUE to the South West Bristol. This approach purposefully conflicts with emerging RSS that has reached an extremely advanced stage of preparation. The Core Strategy cannot achieve conformity with RSS in this regard and therefore would be unsound.

It is confirmed within the CS that development at SW Bristol is not provided for and therefore the overall housing figure is reduced to 17,750, thus creating a 9,000 shortfall within NS.

This approach has wider implications in terms of the overarching objectives set out within National Planning Policy Statements 1 & 3, emerging Regional Spatial Strategy and this Core Strategy. The growth agenda is founded upon proven need. Failure to plan and provide for homes, infrastructure, community facilities and social facilities will result in a demonstrable undersupply of homes, including affordable homes together with essential community infrastructure. In essence the approach advocated with the CS will deny people the right to a decent home and will also undermine the social and economic well being of the regions' community.

The reason given by NSC for not progressing the policy framework for delivery of Bristol SW SUE is "uncertainty". This is not a legitimate reason as it is unfounded in respect of the Bristol SW SUE. The first draft RSS proposed the SUE comprising 10,500 homes, this has remained unchanged throughout the whole of the consultation and examination process into RSS and was unaltered by the Secretary of State in the proposed changes. For this reason the Bristol SW SUE policy within RSS has significant weight and therefore the NSC CS should offer genuine opportunity for consultation on a policy delivery framework.

Mindful that RSS seeks delivery of all its component policy by 2026, NSC should either withdraw the CS at this stage and reissue it as expeditiously as possible or issue an addendum for immediate consultation in order that the responses can be taken account of in the next iteration of the CS.
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