3.1 The housing requirement in Local Plan Part I provides the starting point for considering the delivery levels to be obtained from sites in this Plan. It also forms the basis for the calculation of the five year housing supply.
3.2 The Part I Plan establishes a requirement of 420 dwellings per annum over the period from 2011 to 2029. This was tested through the Local Plan examination and takes into account national household projections, assumptions about long term migration rates and other factors.
3.3 Since the Plan was adopted, the Council have published two studies which provide an updated picture of housing need in the district and the extent of the local Housing Market Area (HMA). The findings of these studies do not replace the adopted plan figure but are a significant consideration in assessing housing delivery through Local Plan Part II.
3.4 The conclusions of the Housing Market Area study2 demonstrate that Mendip District can be treated as a self-contained HMA. This means that for practical purposes, Local Plans can continue to be prepared for the area to address housing need arising in Mendip without a specific need for joint planning with neighbouring areas.
3.5 The Strategic Housing Market Assessment (or SHMA)3 updates the Mendip Housing Needs study (mid 2011) and the 2011-based housing projections incorporated in Local Plan Part I. It provides an estimate of Objectively Assessed Need which is the level of housing required in a HMA before any constraints (such as planning policy or land supply) are taken into account.
3.6 The SHMA 2016 concludes that OAN can be considered as reasonable and justified within a range of 411 – 491 dwellings p.a. It also recommends that, as a starting point, a level towards the higher end of the range would be more robust. This takes into account sensitivity testing using alternative assumptions in the projections and a better alignment of housing with job growth.
3.7 In responding to the SHMA, the Council have taken the following approach as to how its outputs are used to inform Local Plan Part II.
3.8 The need to explore higher levels of development than Local Plan Part I also reflects the fact that the dwelling requirements are minima and that a significant proportion of housing needed over the plan period has already been built or is already committed. The Local Plan Inspector in examining Local Plan Part I also considered that there were likely to be sustainable options to increase housing delivery over the adopted plan figure.
3.9 This approach also aligns with the expectations of national planning policy to boost the supply of housing and is more likely to produce a ‘sound’ plan through examination.
3.10 In terms of housing supply, there are a number of principal objectives to be delivered from the site allocations through this Plan. This takes into account national guidance and the policies and approach adopted in Local Part I. These are:
3.11 It is considered these objectives can be addressed through the scope of Local Plan Part II and do not require a complete review of the spatial strategy.
3.12 The plan takes a site-based approach. This means assessing available and sustainable sites to address these objectives rather than revising district and settlement housing requirements.
3.13 LPP1 Core Policy 2 sets out that the district should accommodate at least 9,635 additional dwellings over the period 2006 to 2029. It also sets out minimum housing requirements for the main towns and Primary and Secondary villages. The residual levels of development to meet the district target are set out in the Housing Background Paper, which covers housing supply. In total, Local Plan Part II would need to provide 726 dwellings located in towns and villages with a residual requirement.
3.14 The NPPF requires that each Local Planning Authority demonstrate that there is a five year supply of deliverable sites for housing development. These are specific sites within the overall land supply where there is confidence that dwellings can be delivered in a rolling five year period. Based on the adopted plan target, the requirement equates to demonstrating a supply of 2,055 dwellings (including a 5% buffer).
3.15 The five year supply figure is regularly updated through statements and monitoring reports published on the Council’s website.
3.16 The allocation and release of sites in this Plan will make a significant contribution to maintaining a five year supply over the longer plan period to 2029 and particularly in Years 5 – 10 (from 2022-2027).
3.17 An assessment has been made of the likely timings of construction of the various supply sources to produce a trajectory of dwelling completions. Housing trajectories are site by site estimates of delivery and start and finish dates for a development. Combining housing trajectories for each settlement demonstrates that the plan can deliver in excess of five years supply of land to well beyond the timing of the next Local Plan Review4.
Objective (c): To increase delivery of affordable housing
3.18 Evidence from the 2016 SHMA re-iterates the need to make the maximum use of the development plan to deliver affordable housing and particularly housing for social rent. However, the expectations in the Part I Plan of increased delivery through small sites has been compromised by government policy to generally exclude sites under 10 units from contributing to delivery of affordable homes. Added uncertainties to the corporate plans of Registered Providers have also added to delays on securing and delivering homes on larger sites.
3.19 Policies in Local Plan Part I are intended to deliver 2,500 affordable homes over the plan period. The allocations identified in Tables 1 and 2 should contribute 747 affordable homes in compliance with Policy DP11. 1,201 affordable homes have been completed between 2006 and 2019. The housing trajectory, which includes sites allocated in this plan, together with existing and potential commitments should provide around 1,274 affordable homes to the end of the plan period in 2029 and 1,390, dwellings over the next 15 years. Additional affordable homes would also be expected from windfall sites.
3.20 A refreshed Somerset Housing Strategy will provide a basis for developing a policy response to housing need for specific groups – particularly the need for older-age households. It is considered there is sufficient flexibility within adopted Local Plan Part I policy for any revised Council’s approach to be set out in Supplementary Planning Documents. If specific development management policies are required these will be included in the Local Plan review.
Objective (d): To achieve a distribution of growth consistent with the spatial strategy
3.21 The Part I Local Plan directs development to the five towns (Frome, Glastonbury, Shepton Mallet, Street and Wells) and a proportion to the 16 larger villages with local facilities (identified as Primary Villages) and a group of 13 Secondary Villages. A principle of this Plan is to allocate land to support this distribution.
3.22 The Plan allocations therefore focus on those settlements where land supply falls short of the minimum requirements. It also seeks to prioritise suitable and sustainable sites in the towns over village locations.
3.23 In addition to requirements for towns and the rural area, Core Policy 2 also identified a need to distribute a further 505 dwellings in towns and villages as a consequence of rolling forward the plan period to 2029 (see also para 4.21 in Local Plan Part I).
3.24 Outside the five main towns, Local Plan Part I indicates (in para 4.7) that land on the edge of the district near Westfield, Midsomer Norton and Radstock could be identified to meet housing need in Mendip. This has resulted in additional allocations around Midsomer Norton (see section 10.6) and in Primary villages in the north/northeast of the district.
Objective (e): To provide for an uplift in housing growth
3.25 This Plan does not seek to review the adopted dwelling requirement as this will be addressed in the future Local Plan Review. However, the potential delivery from site allocations can be compared against the findings of the 2016 SHMA. For example, applying the highest level of OAN in the SHMA (490 dwellings per annum) over the plan period from 2014 – 2029 would result in a revised plan target of 10,685 dwellings – an uplift of around 11% on the adopted plan.
3.26 Table 3 shows that potential delivery based on the capacity of the site allocations in this Plan, together with other sources of supply could provide approximately 11,200 dwellings.
3.27 An important part of the spatial strategy is that there should be a proportionate approach to growth in the designated Primary and Secondary villages. However, a number of villages have seen significant additional development built or granted permission. This reflects the impact of a period where the Council was not able to demonstrate a five-year housing land supply.
3.28 The approach of this Plan is that further growth in these villages through planned site allocations does not reflect the adopted spatial strategy. The proposed site allocations reflect this principle by not identifying allocations in villages which have already fulfilled the requirements set out in Local Plan. However, small residential development schemes on sustainably located sites within all Primary and Secondary Villages, will in principle be acceptable, subject to environmental and infrastructure considerations and impact on the living conditions of neighbouring residential occupiers.
3.29 Monitoring data at a district level indicates a marked shift in the balance of housing delivery to the rural area. This supports the case for the emphasis of this plan to be on allocations in the Mendip towns. The residual housing numbers quoted for villages in the Plan are based on 2017 surveys.
3.30 In preparing Local Plan Part II, the Council have considered the impact of the spatial strategy on settlements which are not identified as Primary or Secondary villages. These settlements lack the range of facilities and services to be considered as sustainable locations for growth – although housing can come forward under the exception policy (DP12) to meet local affordable need. Policy DP24 which promotes single-plot exception sites, will provide additional flexibility in these settlements for lower-cost market housing.
3.31 The Council intends that a review of the rural settlement hierarchy is best accomplished through the future Local Plan Review. This would allow for a comprehensive district-wide re-assessment of transport and other relationships between villages and the main towns. This cannot be achieved through promoting or demoting individual villages in the hierarchy in Local Plan Part II.
3.32 The Council continues to monitor the level of services and facilities in smaller settlements, and this can be taken into account in deciding individual development proposals. Further information can be found on the Development Monitoring page of the Council website.
3.33 The identification and selection of sites in this plan has followed a structured approach.
3.34 All councils are required to maintain a register of land that has been put forward for Development. This is referred to as the Housing and Employment Land Availability Assessment (HELAA). HELAA sites provide a starting point for development but this does not mean any particular site is developable or suitable for development; either in part or whole.
3.35 Housing sites not included in the HELAA may possibly be capable of development. However, because neither a developer nor landowner has promoted the site as available, these sites cannot generally be considered as options in the site allocations process. As the HELAA tends to be focused on greenfield land, a more flexible approach has been taken for employment sites and more complex sites such as those in town centres.
3.36 The settlements suitable for development are defined in the Spatial Strategy - Core Policy 1 of the Local Plan Part I. This includes the five principal settlements of Frome, Glastonbury, Shepton Mallet, Street and Wells, alongside the Primary and Secondary villages. No allocations were proposed outside these settlements. Allocations on the boundary of Mendip and Bath & NE Somerset were made through the examination process.
3.37 Those sites put forward by landowners and developers for inclusion in the 2014 HELAA were the subject of an initial desktop assessment. This was to establish whether sites were subject to constraints which would rule out housing development for example being located within Flood Zone 3; within a Special Landscape Feature; very steep topography etc.
3.38 A number of sites from the HELAA were ruled out at this stage and the results were published as part of the Issues & Options Consultation Document in 2015. A number of new sites were put forward as part of the consultation process and an opportunity was provided for landowners to submit further evidence.
3.39 The sites that were considered suitable after the initial sift of Stage 2, alongside the new sites put forward through the Issues & Options Consultation, were then subject to Sustainability Appraisal (SA). The SA framework contains a series of objectives that cover the likely environmental, social and economic effects of development. The performance of each site was assessed against each of the objectives using a consistent set of decision aiding questions. The sustainability appraisal used common evidence and the process ensures a transparent, consistent and equitable comparison of all reasonable alternatives.
3.40 The appraisal process ruled out some sites and left a number of sites considered to be suitable as preferred options. Further information is set out in the Sustainability Appraisal.
3.41 In those settlements where allocations were required an informal consultation on the preferred options took place with Town and Parish Councils from December 2016 – February 2017. Where a choice needed to be made between a number of preferred options the views of the Town and Parish councils, alongside views expressed by respondents to the 2015 Issues & Options Consultation, were taken into account in choosing a site for allocation.
3.42 The preferred options were reviewed, informed by high level assessments from infrastructure providers, additional ecological advice and the Habitat Regulations Assessment. Broader judgements on the role of development sites to fulfil district growth objectives, community aspirations and policies in neighbourhood plans were also taken into account in the shortlisting of sites.
3.43 An assessment has also been made as to whether preferred sites were capable of delivery taking into account policy obligations such as affordable housing and necessary infrastructure. Further information is contained in the Infrastructure Delivery Plan.
3.44 The potential level of housing delivery from shortlisted sites was compared with the higher growth targets indicated by the findings in the SHMA and the overall level of uplift was tested through the Sustainability Appraisal. This assessment supports the position that growth objectives can be achieved within the principles set out in the adopted Local Plan Part I.
3.45 Sites for housing or housing-led development in the Mendip Towns and around Midsomer Norton are identified in Table 1. The sites are allocated to support the role of these centres, increase delivery of affordable housing and ensure a rolling five-year housing land supply. The selection of sites has been informed by Sustainability Appraisal, housing delivery and community objectives.
3.46 The specific requirements and the form development will take are described in the individual site allocation policies in the Settlements chapter of this Plan. This is to ensure they are each appropriate in scale and character to their location and in accordance with Local Plan Part I and national policy.
3.47 A Future Growth Area is identified in Street. This is to provide flexibility in determining the extent of development and strategic open space which will come through master planning work. This is explained in Policy ST3.
3.48 The Future Growth Area in Frome identified in Local Plan Part I is not being retained and will be reassessed as part of town-wide options in the future Local Plan Review.
3.49 The housing sites in Table 2 are allocated in Primary and Secondary villages in Mendip. The sites are allocated to achieve the objectives of the spatial strategy and to meet the village development requirements set out in LPP1.
3.50 The selection of sites was informed by the Sustainability Appraisal which accompanied the development of the Plan.
3.51 The specific requirements and the form each development will take are described in the individual site allocation policies in the Settlements chapter of this Plan. This is to ensure they are each appropriate in scale and character to their location and in accordance with Local Plan Part I and national policy.
3.52 In addition to the allocations made in this Plan, additional housing delivery will come forward through a number of planning policy measures and initiatives. These include:
3.53 A number of brownfield sites are allocated in the towns for housing or mixed use. Some brownfield sites in employment use have not been allocated, reflecting a strategic need to retain land for economic development purposes in central locations.
3.54 Land at Saxonvale, Frome has recently been acquired by the Council. A planning application for mixed use redevelopment has been approved in principle.
3.55 The Council is required to publish a brownfield register which identifies policy-compliant sites which are suitable for housing-led development and which have not started. Nearly all of these sites are existing commitments and already included in the housing trajectory. The Council will continue to explore options and invite suggestions for brownfield sites through the consultation process on the Local Plan review and other initiatives.
| Settlement | Local Plan Part II Policy Reference | HELAA Site Ref | Minimum Dwellings |
|---|---|---|---|
| Frome | |||
| Saxonvale (*1) | FR1 | FRO009 | 250 |
| Land N and S of Sandy’s Hill Lane | FR2 | FRO152M | 250 |
| Land S of Little Keyford & The Mount | FR3a | FRO001/150/150a | 325 |
| Little Keyford | FR7 | FRO004 | 20 |
| Glastonbury | |||
| Highway Depot & Avalon Motors | GL1/1a | GLAS001/1a | 67 |
| Allotments, Lowerside Lane | GL2 | GLAS119 | 50 |
| Frogmore Garage | GL3 | GLAS027 | 25 |
| Lintells & Avalon Garage | GL4 | GLAS055/GLAS121 | 25 |
| Street | |||
| Land West of Somerton Road | ST1 | STR003 | 280 |
| Land adj Street Cemetery | ST2 | STR137 | 32 |
| Land West of Brooks Road – MDA (*2) | ST3 | STR001/WAL026 | 400 |
| Wells | |||
| Land off Bubwith Walk | WL1 | WELLS044 | 120 |
| Wells Rugby Club | WL2 | WELLS094 | 80 |
| Tincknells Depot | WL4 | WELLS116M | 25 |
| Land of Elm Close | WL5 | WELLS084 | 100 |
| Total Dwellings | 2049 | ||
| (*1) Revised boundary from land allocated in LPP1 Policy CP6b | |||
| (*2) Main Development Area shown in Policy ST3 – revised boundary from LPP1 Allocation CP8a | |||
| (*2) Policy ST3 – Capacity of Future Growth Area to be confirmed through masterplanning | |||
| Settlement | Site Name | Local Plan Part II Policy Reference | HELAA Site | Dwellings in allocated sites |
|---|---|---|---|---|
| Binegar & Gurney Slade | Land Off Station Road | BG1 | GS001 | 11 |
| Butleigh | West View, Sub Road | BT1 | BUT003 | 25 |
| Coleford | Land s.o Recycling Centre | CL1 | COLE024 | 21 |
| Coxley | Community Centre | CX1 | COX030 | |
| Ditcheat | Land on Edge of Ditcheat | DT1 | DIT008 | 16 |
| Ditcheat | Land at Back Lane (*1) | DT2 | DIT009 | 0 |
| Draycott | Land N of Westfield Lane | DR1 | DRAY004a/22 | 33 |
| Mells | Part Hill House, Woodlands End | ML1 | MELLS002 | 4 |
| Nunney | Land at Green Pits Lane | NN1 | NUNN01a | 70 |
| Stoke St Michael | Land East of Frog Lane | SS1 | SSM009 | 30 |
| Westbury Sub Mendip | Land S. of Roughmoor Lane | WM1 | WSM006 | 40 |
| Total | 250 | |||
| (*1) granted permissions and shown as ‘0’ to avoid double counting in Tables 3 and 4 | ||||
3.56 The proposed allocations in this Plan provide 1,776 additional dwellings over the Plan period to 2029. Together with the remaining sites identified in LPP1 (1,150 dwellings), the combined site allocations will provide 2,916 dwellings.
3.57 Table 3 shows delivery by settlement over the plan period to 1st April 2019, and the level of commitments, site allocations and other developable sites as at 1st April 2019. This does not include windfall development or housing which may come forward in the Future Growth Area in Policy ST3.
| Net Dwellings | Completions | Commitments | Part I & 2 Plan Allocations | Other sites | Planned Growth | |
|---|---|---|---|---|---|---|
| 2006-19 | Started | Not Started | ||||
| Frome (*1) | 1502 | 195 | 294 | 845 | 44 | 2880 |
| Glastonbury | 636 | 142 | 91 | 167 | 0 | 1036 |
| Street (*1) | 803 | 52 | 13 | 712 | 0 | 1580 |
| Shepton Mallet | 727 | 5 | 181 | 600 | 30 | 1543 |
| Wells | 802 | 312 | 309 | 345 | 0 | 1768 |
| Primary Villages | 750 | 75 | 126 | 236 | 24 | 1211 |
| Secondary Villages | 386 | 38 | 109 | 11 | 0 | 544 |
| Other villages & Countryside | 527 | 113 | 123 | 20 | 783 | |
| Total | 6133 | 932 | 1246 | 2916 | 118 | |
| (*1) includes sites part allocated in Local Plan Part I – Saxonvale (FR1) and Land west of Brooks Road (ST3) | ||||||
| (*2) delivery from allocations scheduled to commence in remaining plan period 2019 - 2029 | ||||||
3.58 Table 4a compares the level of planned growth by settlement to the minimum requirements in the adopted Part I Plan. Frome has the highest level of growth reflecting the availability of preferred options and other sites. Glastonbury is particularly constrained. The uplift in the rural area from Local Plan Part I reflects the impact on unplanned growth in villages when the Council was not able to demonstrate a five year supply.
3.59 Planned growth is expected to deliver a total of 11,345 dwellings which equates to a 15% uplift over the minimum district requirement of 9,635 dwellings in the Local Plan Part I.
3.60 Table 4b illustrates dwelling delivery from planned growth and windfall over the 5-year period (2019 – 2022) and from Years 6 – 10 and then beyond the plan period.
| Dwellings | CP2 Minimum Requirement 2006 – 2029 | Planned Growth 2006 – 2033/34 (*1) | Change from Policy CP2 |
|---|---|---|---|
| Frome | 2300 | 2880 | 25% |
| Glastonbury | 1000 | 1036 | 4% |
| Street | 1300 | 1580 | 22% |
| Shepton Mallet | 1300 | 1543 | 19% |
| Wells | 1450 | 1768 | 22% |
| Villages & rural | 1780 | 2538 | 43% |
| Total | 9635 (*2) | 11345 | 15% |
| Windfall 2020/21- 2029 (*3) | 900 | ||
| Total uplift | 9635 | 12245 | 27% |
| Source: Mendip Housing Trajectory (November 2019) | |||
| (1*) Includes completions to 2019 plus + delivery from commitments, LP1 and LP2 allocations and developable sites to 2029 | |||
| (2*) Total includes unallocated 505 dwellings | |||
| (3*) Estimated at 100 dwellings per year | |||
| Settlement | 5 year period 19/20 – 23/24 | Remainder of Plan Period 2024/25 – 2028/29 | Beyond Plan period 2029/30 – 2033/34 | Total |
|---|---|---|---|---|
| Frome | 648 | 710 | 20 | 1378 |
| Glastonbury | 233 | 105 | 62 | 400 |
| Street | 207 | 430 | 140 | 777 |
| Shepton Mallet | 202 | 356 | 258 | 816 |
| Wells | 641 | 305 | 20 | 966 |
| Primary Villages | 225 | 214 | 22 | 461 |
| Secondary Villages | 147 | 11 | 0 | 158 |
| Other villages/countryside | 245 | 11 | 0 | 256 |
| Total Planned Growth | 2548 | 2142 | 522 | 5212 |
| Windfall allowance | 400 | 500 | 500 | 1400 |
| Total Growth with Windfall | 2948 | 2642 | 1022 | 6612 |
3.61 A Sustainability Appraisal (SA) has been undertaken to consider the cumulative impacts of the uplift in the towns and in the district resulting from the allocation of all of the preferred options sites. While some impacts are highlighted, these are considered acceptable provided mitigation is provided on the individual sites.
3.62 The SA also compares the impacts of the allocation of all the preferred sites in Frome, Glastonbury, Street and Wells against an option of just meeting the minimum housing requirements in Local Plan Part I. However, this approach would not achieve the objective of delivering a rolling five-year supply over the plan period. The SA concludes that the impacts of uplifts proposed are not so significant that the lower growth option should be preferred.
2 Housing Market Areas and Functional Economic Areas in Somerset (ORS) Sept 2015.
3 Mendip, Sedgemoor, South Somerset & Taunton Deane – Strategic Housing Market Assessment (Oct 2016), JG Consulting
4 See Testing Housing Supply Background Paper which shows a provisional housing trajectory.
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