Q1: Does the proposed strategy make adequate provision to address the housing needs of WoE?
No. There is a fundamental problem of housing affordability, which this strategy does not meet. There needs to be more of a focus on affordable homes, and land for subsidised housing. As of 2013 data from DCLG, the ratios for house prices to earnings across the West of England were all in the top half of the country, ranging from 7x in North Somerset to nearly 9x in BaNES (compared to 3.2x in 1997 when the datasets begin). This strategy is not responsive to the West of England's need for affordable housing well located in relation to centres of employment.
This document is a missed opportunity. Rather than setting out an integrated vision for the WoE area it is entirely focused upon making do – and offers more of the same entirely focused upon delivering housing numbers, rather than being strategic about the future of the area. In particular, it fails to address the key economic challenge of the WoE area, which is the overheating of the economy to the north of the area and the need for economic investment for the south Bristol to Weston corridor.Indeed it will worsen the north Bristol overheating . We do not believe this strategy will do anything significant to address that core issue of jobs and economic prosperity for Weston and south Bristol. We do not believe it can be addressed by piecemeal incremental development of either housing or employment allocations. It requires a visionary and radical approach that will inspire internationally and deliver the sort of integrated employment and residential communities we have seen cities across Europe develop in response to regeneration needs. We bitterly regret that this plan makes it likely that Weston and south Bristol will have the same unemployment levels in 20 years time as they do now and a major opportunity will have been missed.
Q2: How can we increase the delivery of homes, in particular much needed affordable homes in the West of England?
Thereis a need for affordable housing but this strategy lacks any vision for how this might be addressed. Placing strategic development in locations which are already experiencing substantial development levels like Yate will result in risks overheating the local market. There is a severe risk of getting the worst possible situation of this land being allocated for housing, and then deliverability issues meaning the five year supply cannot be demonstrated.
On the A432 corridor where the market has already had over 1000 new properties since 2010 and already has 2600 committed at North Yate, there is no evidence that this sub market can cope with a further 4100 – a reliance on this corridor puts at risk delivery of the entire numbers. This plan expects the community and the market to be able to absorb 7,700 new dwellings, a growth of over 40% without any strategic vision about employment, physical infrastructure or facilities – this is an extremely unlikely prospect. The document does not recognise let alone offer any means of addressing that massive problem. Deliverability depends on the availability of a wide range of facilities not just housing land allocation. We note that even 18 months after the final grant of consent for the Core Strategy allocation at Yate no construction has started, indicating the difficulties and delays in bringing sites to market in this particular corridor. The delays have been the result of developer decisions not planning authority decisions.
Sustainable development means any land allocated in the plan should be delivered by a wide variety of developers, and particularly small developers who should be supported. Increased speed of delivery, and total delivery of affordable homes is not merely a land use issue, and fiscal means should be explored to facilitate self-procurement and self-build, ensuring it is not only available to wealthy parts of society.
Q3: Does the proposed strategy make adequate provision to address the economic and employment needs of the WoE?
No, as the locational relationships between housing and employment need to be addressed. In particular, focusing the future employment in the Enterprise Zones and Areas, whilst planning housing for elsewhere, requires additional traffic between these locations. It builds in additional massive infrastructure costs of transportation to employment. High quality and high wage employment is needed in the Yate area, which could be achieved through developing older sites already providing employment, whereas we have seen over 1000 dwellings in the last 5 years all on the redevelopment of former employment sites.
The 2600 houses already consented at North Yate did not make a proportionate allocation of employment land, relying instead on a balancing figure of home working, which has not been achieved anywhere in Europe to date. Not least because the necessary infrastructure for home working e.g. the latest broadband speeds are not available.
We note that ALL of the strategic employment sites lie INSIDE the Green Belt, whereas all of the strategic housing sites lie outside the Green Belt or in the Green Belt. This is a fundamental strategic issue, and builds in across the entire area massive transportation costs. This is also an equalities issue, as the cost of commuting has a far higher marginal impact on real earnings for low income families. So, we consider it essential that Yate is regarded as a strategic employment area, with an emphasis upon a diverse range of employment opportunities. A mentioned above, high quality and high wage employment is badly needed in the Yate area, which could be achieved through developing older sites already providing employment, whereas we have seen over 1000 dwellings in the last 5 years all on the redevelopment of former employment sites. In particular the intensification of the large employment area west of the town through a major enterprise initiative could seek to redress the job / housing balance, reduce commuting and address the impact of the cost of commuting upon local poverty. We would strongly urge that the housing allocated to the A432 corridor is located in one of the enterprise areas, and that an enterprise priority is allocated to Yate. We would far rather be in a position having the ability to work in our town and not commute. The existing outstanding consent for over 2600 houses will meet our needs.
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Q4: Does the preferred spatial strategy and the locations identified meet the plan's strategic priorities and vision?
No.
Our town, Yate, wants
- Jobs that are accessible and well paid with minimum travel to work problems / cost
- Homes they can afford
- Facilities to meet local needs
- Reduction in congestion/ public transport improvements so getting about is easier
This plan does nothing to address those. It focuses new jobs in places the other side of the Green Belt from Yate – forcing locals to commute and cutting net income through commuting costs. It will not deliver affordable housing and will just dump more unaffordable houses into town. There is no proposal to provide the sort of radical change of facilities that a 40% growth in our town would need. It does have some transport proposals, but given we have had NO strategic transport investment since we successfully fought to get our station re-opened in 1988, since when over 2000 new houses have been built and 2600 more consented, we regard the limited investment proposed as catching up on a generation of non investment. The amount being proposed for transport does not address existing problems, let alone provide headroom for the future, and it does nothing to address transport within the town.
We have also had a net loss of jobs, despite the growth in our town in the past 6 years. We need this reversed, through an employment allocation with strategic investment in jobs.
Let us be quite clear. We are fundamentally opposed to any further residential development on the A432 corridor / Yate catchment. There are consents for 2600 houses in North Yate which have not yet started construction, and we have had over 1000 houses since 2010. We need a breathing space. We desperately need time to absorb these 3600 dwellings, which add 30% to the size of the town, to adjust the social infrastructure and social resilience to cope with this growth and ensure those new residents are incorporated and welcomed into our town. We need facilities including transport, roads and services to catch up. We successfully argued for a breathing space in the 1988 plan, and we used that time well. We are now in a position of asking the same again. Give us space to cope with what has already been given consent. Let us adjust as a community.
The stated priorities are to accommodate economic growth objectives, ensure all sections of community benefit, to protect and enhance the environment, and properly align development with infrastructure.Within South Gloucestershire, this strategy does nothing for the priority neighbourhoods of Kingswood and Staple Hill. Across the West of England, there is nothing to address problems in south Bristol, or in Weston super Mare.
The distribution of new housing over recent decades has not solved the problem of the relative underperformance of the economy in Weston and south Bristol. This can only be resolved through a major strategic approach. Allocating land north of Bristol will do nothing to address these issues, and will detract investment from the Weston to Bristol corridor.
If the same level of development were to be located south west of the city, the transport links would be better, the distances to travel would be shorter, and the open spaces for water management would be retained nearer the city in the north, and still with extensive open green spaces around the south west. We have set out below our thinking on this.
As there is no delivery programme for housing development, we cannot possibly know if the infrastructure will be delivered in the appropriate timescales. Land is being released for development with no indication that there will be funding for the infrastructure needed.
There are discrepancies between the transport infrastructure proposed in the Joint Transport Study, and the more limited proposals identified as requirements for development in the Joint Spatial Plan. For example, in the north east of Bristol, the JTS proposed a new motorway junction on the M4 and a link road from there to Yate. It states that this link road and prioritising Badminton Road for buses and bicycles form a package needed to make the metrobus plans work. However, the JSP identifies the metrobus extension, but not the link road as requirements for development around Yate and Coalpit Heath. Without the link road, traffic from the 1500 homes at Coalpit Heath, and at least some of the 2600 at Yate would have to use the Badminton Road and given the lack of road space, it would be difficult to then prioritise the Metrobus. This cannot be expanded without substantial engineering and demolition around the existing constraints, such as landscape and buildings.
The issues of location also have sustainability implications. If low cost housing is provided a long way away from city employment locations and the Enterprise Zone and Areas, which are expected to provide two thirds of all employment needed, then people must pay to get to their work – whether it be through petrol or public transport fares. This will offset many of the savings from the housing itself and makes it difficult to call any such housing affordable or sustainable. It has a regressive effect and depresses the income of the poorest in work, making work less attractive. The increased traffic this will generate has environmental and social implications, as air pollution is one of the biggest causes of early deaths. This works against both ensuring all sections of the community benefit, and the environmental aims.
These issues all tie together to threaten the economic growth objectives.
The objectives clearly coming from the consultation indicated that protecting the Green Belt was a top strategic priority. This appears to have been ignored as far as the area between the edge of urban Bristol and Yate is concerned, where significant development is proposed in one of the narrowest strips of Green Belt.
It is stated that “The enterprise zone and areas have capacity to support the provision of up to 78,400 jobs depending on end uses. This is more than two thirds of the identified employment growth of 82,500 across the plan period” – Unfortunately this will make the commuter traffic situation appreciably worse in the A432 corridor and A38 Thornbury area, which does not have the enterprise zone and areas and their new higher quality jobs.
The present proposals for the different distributions of employment (based on the W of E Local Enterprise Partnership Strategic Economic Plan) and housing (based on the JSP) will force people into commuting long distances along already severely congested routes.
All the key employment sites lie INSIDE the Green Belt. Of the 10 strategic housing locations, 7 lie outside the Green Belt and 3 in the Green Belt. This builds in an unsustainable cost - the financial cost of the transportation infrastructure to cover the gap between housing and employment locations - which has a massive public infrastructure cost as well as developer funding. In addition there are significant environmental impacts. The evidence suggests that air pollution is the single biggest preventable cause of early death - so why are we building in all this commuting?
It also runs completely counter to the region’s aim to be an inclusive as well as sustainable region. The research data shows that when you locate new housing (which tends to be cheaper than the larger older houses in the centre of the city) at a distance from the employment opportunities you are INCREASING inequality. Put simply, you are putting the less well off in housing that has built in extra costs of getting to decent wage employment locations, and so they either have more travel to work costs OR end up working in low wage jobs in the immediate locality. This undermines inclusion.
So, at the very least, the plan must swop some sites around so some of the housing sites are city side of the Green Belt, so as to make travel to work more efficient.
“Further third of employment will come through the needs of the increased population including; GPs, shops and leisure uses” – Most of these jobs will be at or near the minimum wage level – the proportion of such jobs in the Yate/Sodbury area is already too high. The change of population in the Yate catchment area across the 2010 – 2030 period will be nearly 40% and that cannot be accommodated without major service sector provision as well as in town radical physical infrastructure improvement. There is no physical space in the town for that more radical growth and the strategy makes no reference to that as a constraint upon any potential development.
Attention should therefore be paid to planning and incentivising quality better-paid employment in the Yate/Sodbury conurbation, possibly by redevelopment of older employment areas.
Considering both “Yate strategic corridor (Yate/Chipping Sodbury)” and Coalpit Heath, our comments on the “likely transport mitigations” are:
-Station improvements – we have been promised these improvements for many years, in successive plans, but they have not been delivered. Our current services often leave people on platforms with trains too full to squeeze people on, so there is a risk these proposals will just deliver a catching up not a radical improvement. We welcome the proposals, as a contribution to sorting out the problems but are concerned try to ensure this is not seen as a solution to commuter issues as it only serves about 2% of commuters
-MetroBus – It is noted that this would be “ordinary buses”, and we have very recent local history of bus services being reduced and eliminated by First Bus, without any constraints. The Metrobus services must have a firm contractual basis to make sure that this does not happen again. It is unclear how space will be found for it in the urban area, given the 40% growth of population and therefore town centre pressure.
-Park and Ride – This has been promised for so long that the land originally zoned for it is now not large enough. The original concept was that it would only be served by the buses that were passing anyway on the main road. Therefore the Park and Ride needs to be much better integrated into the Metrobus system., and needs to be provided immediately.
-Pinchpoint schemes and junction improvements – Not enough information about what you see as pinchpoints has been provided to enable us to comment.
-We are extremely concerned that there is no mention of any work to address traffic and transport problems with the Yate /Sodbury conurbation. You may consider that a ‘ detail’ but it is not more of a ‘detail’ than addressing ‘pinchpoints’. We consider the document should recognise the need to invest in a traffic and transport project within the town as well as between the town and other locations. The two are inextricably linked, not least given the plan appears to show the Metrobus running right through the town centre, reducing highway capacity.