Draft Core Strategy (incorporating Preferred Options) October 2010

Document Section Draft Core Strategy (incorporating Preferred Options) Introduction Evidence Base Evidence Base [View all comments on this section]
Comment ID 1340
Respondent P J Burrows [View all comments by this respondent]
Response Date 30 Nov 2010
Response Type OBJECT
What is the nature of this representation?
  • Object
Comment
'Out of Date' Data and Unquantified Evidence

Section 1.16 states:
"The Government requires that policies and proposals are soundly based on current evidence. There has been considerable evidence gathering across the full range of issues and matters that has been used to shape the Core Strategy policies and proposals."

One of the most significant drivers to shaping the policy is the forward projection of population growth and associated housing demand in the area. I have major concerns that the proposals put forward are predominantly aspirational and not related to the likely demand for growth. It is not just the scale of the Core Strategy proposals that are affected by changes in growth levels, these can change the shape of the policy itself.

The Core Strategy (Section 4.41) references an ONS projection (based on 2008) for 19,700 dwellings. My examination of ONS data finds that they indicated a projected population growth for South Somerset of around 0.65% to 0.7% pa for the period under review. This would be mainly from inward migration and resulting almost uniquely in a growth in the retired age group. This means that housing demand would increase and the mix would change but that employment demand would not be radically increased. However, since 2008, major global and national economic changes with relatively long term effects and more recent changes in national policy would indicate that more up to date forecasts will give a much lower figure for population growth in this region.

There are factors which tend to increase housing demand, such as an increase in single parent families and a desire for different family generations not to share the same dwelling. Even if these lesser factors were to offset economic and policy-driven trends, which is very unlikely, a projected growth in housing of 0.65% pa would only increased the housing levels of South Somerset from 71,400 currently to 79,200 by 2026. This increase of 7,800 is far below any of the three figures (13,600, 16,600 and 19,700) used by the Council in its study. The Council rationale in this process has not been adequately explained and the growth proposals appear to be purely aspirational. As such, and in view of factors such as significant future economic risks, it needs to be fully re-evaluated and re-presented for public assessment.

The use of non-current data and the limited evidence presented means that significant aspects of these proposals would appear to have no sound basis. They present an unacceptably high risk and should be withdrawn and restructured in a manner more appropriate to current demographic and economic forecasts.

1.16 The Government requires that policies and proposals are soundly based on current evidence. There has been considerable evidence gathering across the full range of issues and matters that has been used to shape the Core Strategy policies and proposals.
The proposals are not based on current forecast for population growth and economic factors. Also no up to date traffic analysis and resultant forecast has been included. The proposal is therefore not soundly based and should not be presented for public examination nor proceed to the next stage until such data has been updated and established.
The evidence that has been gathered, mainly included in the Sustainability Appraisal, is not easily available for public examination (see above).
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