1        INTRODUCTION

1.1     This document sets out the background, methodology, results and site details of the Urban Housing Capacity Study for Bath & North East Somerset. Work was originally undertaken with a base date of April 2000, as part of a jointly co-ordinated study within the Joint Replacement Structure Plan (JRSP) area, comprised of the unitary authority areas of Bath & North East Somerset, Bristol, North Somerset and South Gloucestershire.  The study has now been updated to April 2004.

1.2     Government policy (set out in PPG3: Housing) seeks to maximise the re-use of previously developed land and buildings for housing, in order to promote urban renewal and also to minimise the amount of greenfield land taken for development.  Urban housing capacity studies are seen as important tools in aiding the identification of sites suitable for housing and therefore the process of urban regeneration.

1.3     The Urban Housing Capacity Study (UHCS) differs from the Residential Land Study, which relates to land available for residential development in all parts of the District including the rural areas.  The UHCS relates only to land and buildings within the urban areas and is an assessment of housing ‘potential’, resulting in an estimate of the amount of housing each urban area can accommodate over a stated time period.

1.4              The assessment requires an understanding of the processes of urban change and the opportunities that it may present.  These processes are dynamic and therefore views of potential will need to be carefully monitored and will change over time. As such this work forms an important element of the ‘plan, monitor and manage’ approach to housing provision.

1.5              The study involves making policy judgements about the suitability and feasibility of individual sites for residential or other development.  A wide range of policy issues need to be considered including the social impacts of development, the need and demand for other uses and environmental and infrastructure impacts.  Therefore, the UHCS is not merely a technical exercise aimed at identifying the maximum level of housing capacity, but is an examination of housing potential set within a framework of seeking to secure the long term sustainability of the District’s urban areas.

1.6     It should be noted that the sites assessed and judgements made may need further consideration following consultations with landowners, occupiers, local communities and other interested parties through the planning process.  Therefore, it should not be assumed that planning permission would necessarily be granted at any time for any specific development in respect of the land identified.

2        BACKGROUND AND PURPOSES OF THE STUDY

2.1     The UHCS is undertaken in response to the publication of PPG3, Housing and the associated government objectives of maximising urban housing potential and promoting urban renewal. The initial study in 2000 was also carried out in order to inform the process of responding to the Secretary of State’s Direction on the JRSP.  This required that provision be made for an additional 10,700 dwellings over and above the 43,600 which the Joint Committee for Strategic Planning and Transportation agreed to provide in the JRSP.

2.2     Urban Housing Capacity Studies were undertaken by the four Unitary Authorities to a consistent and agreed methodology in order to assist the process of determining the level of additional housing that could be accommodated and agreeing a revised distribution for this additional housing. Since that time the Bath & North East Somerset UHCS has been updated on an annual basis.

2.3     The UHCS serves a number of important local planning purposes, as follows:

·         informs the development of local plan policies and a brownfield land target for Bath & North East Somerset;

·         helps provide a basis for considering planning applications for residential development (in the light of PPG3) particularly on greenfield sites; and

·         provides a basis for detailed monitoring of development in accordance with PPG3, other recent government guidance and Best Value Indicators.

3        THE APPROACH

3.1     Government guidance on urban housing capacity studies referred to in PPG3 and entitled  ‘Tapping the Potential - Assessing Urban Housing Capacity: Towards Better Practice’ was published in December 2000.  The methodology used for this study reflects the approach set out in the guidance and follows the four main stages set out in it:

identification of the capacity sources - identify the urban areas to be assessed and consider all potential sources of housing

surveying that capacity - utilise existing data and develop survey methodologies to identify opportunities for additional housing

assessing the yield - estimate the theoretical potential number of units that can be accommodated from the sources identified

discounting the potential - make judgements on the target dwelling numbers that might be brought forward from the potential or theoretical capacity within the time period of the study.

Identification of urban areas and capacity sources

3.2     The urban areas covered by the UHCS are:

·         Bath (identified as a Principal Urban Area and therefore a focus for future development in Regional Planning Guidance (RPG) for the South West)

·         Keynsham

·         Norton-Radstock

Land located within each of these built up areas was included in the study.  These settlements, but no others, are classed as ‘urban areas’ in the JRSP.  Therefore, the UHCS does not cover any of the numerous villages within the District and as such did not assess land in ‘urban uses’ within them or other rural locations.

3.3     Ten source categories contributing to housing capacity have been identified:

         1.     previously developed land and/or buildings now vacant; including derelict land and buildings, and abandoned and unoccupied buildings;

          2.     vacant land not previously developed;

          3a.   redevelopment of existing housing;

          3b.   redevelopment of other existing uses;

          4.     development of car parks where under-utilised;

          5.     conversion of commercial buildings;

          6.     living over the shop;

          7.     sub-division of existing housing;

          8.     intensification and development in existing residential areas;

          9.     re-use of empty homes.

3.4     ‘Tapping the Potential’ suggests that existing housing allocations and other existing local plan allocations should be reviewed as part of an UHCS and classifies these sites as two separate source categories. The review of local plan allocations was an integral part of this study, however, the resulting capacity has been classified by the source categories outlined above.  No estimate of capacity arising from the re-use of empty houses has been made because an allowance has already been made for this in setting structure plan dwelling requirements.

          Surveying the capacity

3.5     In estimating urban capacity the main focus was on sites/areas that could potentially produce housing in the period up to 2011 (i.e. the JRSP and local plan period).  However, the estimates do also look forward beyond 2011 in recognition of the need for longer term development and the review of the sub-regional planning framework, including the distribution of future requirements for housing.

3.6     The UHCS makes full use of existing data.  This includes work undertaken for the National Land Use Database (NLUD), Residential and Employment Land Surveys and retail surveys.  Local Plan allocations have been reviewed to consider whether some might be better used for housing or mixed uses.

3.7     The exercise of identifying housing potential also focussed on Priority Areas.  These were areas where urban change is considered most likely to take place and therefore opportunities arise.  They included Bath City centre, Moorland Road district centre (in Oldfield Park) and Keynsham, Midsomer Norton and Radstock town centres and the areas adjoining them which may be in transition.  Other priority areas assessed were the Western Riverside and Upper/Lower Bristol Road areas to the west of Bath City centre.  Assessment of Priority Areas enabled detailed consideration and identification of a comprehensive range of potential opportunities.

3.8     Surveys have been undertaken of opportunities for additional housing.  A combination of methods was used including:

·         detailed analysis of ordnance survey maps, aerial photographs and development control records

·         discussions with development control staff and other Council Services

·         contact with a range of organisations with an interest in the future development of the area

3.9     Within the search framework outlined above a pragmatic and practical approach was adopted to the inclusion of potential sites.  In addition to sites falling within source category 1 (previously developed land and buildings now vacant/derelict) the approach emphasised:

·         inclusion of sites allocated in local plans but still to be developed;

·         uses/sites which were becoming marginal and/or which might be non-conforming in existing residential areas; and

·         sites likely to be affected by major business re-organisations, particularly those within residential areas

3.10    In order to make the work manageable the study focussed on identifying and assessing large sites (i.e. those sites theoretically yielding 10 or more dwellings). These sites make up source categories 1 to 5. Small sites (source categories 6 to 9) were treated separately, as the detailed identification of such sites would represent a time consuming and resource inefficient exercise given the likely yield and inability to influence their delivery.  Estimates of housing capacity likely to come forward from small sites were made.  Small in-fill developments equate to category 8 (intensification of development in residential areas) and estimates were also made for categories 6 (living over the shop) and 7 (sub-division of existing housing).  These estimates were derived from an assessment of overall potential within each urban area, analysis of past completions and the impact of planning policies.

          Assessing the Yield

3.11    The identification of the ‘theoretical potential’ for new housing within the wide range of sites is fundamental to the approach of the study and indeed to a wider and proactive consideration of ‘urban potential’.  The approach ensures that sites and potential capacity are not excluded at an early stage before proper consideration is given to relevant factors and policy judgements made.  This is in line with PPG3 which highlights the need to re-appraise sites not currently allocated for housing and the need to consider various options in relation to such matters as the density of development.

3.12    The theoretical capacity of each site has been calculated using minimum net densities which are set according to the sites’ location. These are as follows:

                   City/town centre site             =100 dwellings per hectare (dph)

                   Urban site (with good

                   public transport accessibility)   = 60 dph

                   Suburban sites                     = 30 dph

          It is important to note that the above densities are minimum figures solely used for the purposes of calculating theoretical capacity.  They do not constrain higher densities being achieved where detailed site assessment showed this to be appropriate.  Therefore, in certain instances the target capacity may be higher than the theoretical capacity, whereas in other cases it could be lower as a result of various factors (see paragraph 3.14 below).

Discounting the Potential

3.13    The final stage of the study was the assessment of how much of this theoretical capacity (if any) is likely to be brought forward and when it might be developed.  This provides an explanation and understanding of the relevant factors that limit the suitability and/or availability of a site for residential development either in whole or in part.  This is a judgmental process, but as stated in government guidance ‘Tapping the Potential’ it is important that it is explicit and not limited by past trends.

3.14    Target capacities for individual sites were shaped by a variety of factors.  These factors included:

·         the demand and need for other uses within each urban area;

·         the physical, environmental and social infrastructure needed to support additional housing;

·         the environmental impacts of development on the immediate and the wider area;

·         accessibility considerations (both vehicular and alternative modes); and

·         site developability, including market viability

In order to gain a clearer picture of the market viability of developing individual sites within each of the urban areas, the JSPTU commissioned DTZ Pieda Consulting to provide economic and market advice.  Their work provided information on the levels of residential demand, impacts of land values for alternative uses and future market prospects for residential development on an urban area basis.

3.15    The process of setting target capacities and explaining the judgements made is important in helping to address a common, but misplaced perception that all vacant urban sites can be readily used for housing thereby ensuring greenfield sites need not be developed.  It also enabled policies constraining housing potential to be identified and their continuing appropriateness to be reviewed as part of local plan preparation.

4        SUMMARY OF RESULTS

4.1     Table 1 below sets out a summary of the estimated housing capacity of the urban areas in Bath & North East Somerset for the period 2004-2011 by source category. 

Table 1: Urban Housing Capacity in Bath & North East Somerset 2004-2011

Source Category	A. Sites shown on the Schedule   2004-2011	B. Total capacity (including unidentified sites) 2004-2011	Percentage of total capacity 2004-2011
1.   Vacant/derelict previously      developed land and buildings	1,226	1,239	49.6%
2.   Vacant land not previously       developed	105	105	4.2%
3a. Redevelopment of existing housing	1	1	0%
3b. Redevelopment of other existing uses	627	760	30.4%
4.   Development of under used car parks	10	10	0.4%
5.   Conversion of commercial       buildings	0	0	0%
6.   Living over the shop	-	10	0.4%
7.   Sub-division of existing housing	-	84	3.4%
8.   Intensification in existing housing areas	-	290	11.6%
9.   Re-use of empty houses	-	-	-
Total	1,969	2,499	100%

Capacity of identified sites and total capacity

4.2     The capacity is summarised in table 1 in two parts. Part A summarises the capacity of the sites identified and detailed in the attached schedule (pages 11 to 29). Part B summarises the total capacity, which in addition to the capacity of the identified sites set out in part A includes an allowance for capacity arising from unidentified sites. In the case of source categories 1-5 (relating to large sites) a number of sites have been assessed where there is no evidence of a confirmed intention to discontinue the current use of the site or where commercial sensitivity makes identification difficult. These sites have not been identified in the schedule as their identification could influence future investment decisions in relation to them. In assessing these sites judgements have been made on the likelihood of future redevelopment, based on factors including location and continuing requirements of the existing use.  These sites have a combined total target capacity of around 150 dwellings, most of which falls within category 3b. 

4.3     Capacity within source categories 6, 7 and 8 has been estimated on an area rather than individual site basis. Therefore, all of the capacity from these sources is shown in part B of the table and equates to an urban small windfall sites allowance.

Spatial distribution

4.4     Overall it is anticipated that the three urban areas in Bath & North East Somerset will provide 2,499 dwellings between 2004 and 2011. Most of the total capacity (almost 85%) will arise in Bath, with the towns of Keynsham and Norton-Radstock making relatively minor contributions of around 130 and 250 dwellings respectively.  This is indicative of the comparative size of the urban areas and the range and size of opportunities potentially available.  In Bath major opportunities exist, including the regeneration of the Western Riverside area, whereas in Keynsham few opportunities exist because of the town’s structure and predominantly residential character. In Norton-Radstock, whilst there are a greater number of opportunities than in Keynsham, many sites within the town have already been developed for housing. Other sites lie within industrial areas, which are unlikely to provide an attractive or acceptable residential environment and are needed in order to provide local employment opportunities.

          Source Categories

          1. Vacant/derelict previously developed land & buildings

4.5     In dwelling capacity terms this category is the most important and accounts for about half of the total urban capacity identified. A substantial proportion of this capacity is accounted for by the anticipated yield from the redevelopment of the Western Riverside area. However, Western Riverside comprises both vacant and derelict land and also sites that are currently in use predominantly for employment purposes. The regeneration of the area is being promoted as a comprehensive development opportunity and hence it is treated as one site categorised under source category 1 within the UHCS. As a result the housing contribution from vacant/derelict sites is artificially high and correspondingly the contribution from category 3b (see below) is lower than that which will be achieved in reality. The redevelopment of the former CIC Ralphs/Clarks industrial site on the south western side of the City for mixed uses, which now has the benefit of planning permission, will make a significant housing contribution.  In Norton-Radstock former railway land in the centre of Radstock represents a major opportunity within the town and the opportunity to develop part of the Somerdale site in Keynsham (currently in recreational/playing field use) is identified.

          2. Vacant land not previously developed

4.6     The development of vacant not previously developed land makes a modest contribution to total urban capacity. This modest contribution is the result of two factors. Firstly, in line with government guidance the local policy framework seeks to protect recreational land and allotments for such uses and therefore these sites were not assessed within the study. Secondly, the study only relates to land within (and not adjoining) the urban areas. Development of sites in the Bailbrook area accounts for most of the capacity identified within this source.

          3a. Redevelopment of existing housing

4.7     The redevelopment of existing housing is anticipated to make almost no contribution to future housing provision within the urban areas. This is because the urban areas in the District are not characterised by large areas of public sector housing that are in need of renewal. Somer Housing (Local Authority Housing Stock Transfer Company) may demolish and redevelop some public sector housing in the future. However, information suggests that dwellings lost would be replaced with a similar number of new dwellings, thereby having little impact on urban housing capacity.

3b. Redevelopment of other existing uses

4.8     The redevelopment of sites currently in use for purposes other than housing is anticipated to make a significant contribution towards realising urban housing capacity (contribution will be greater than the 30% set out in table 1, see category 1 above).  Major potential opportunities lie within Bath e.g. the redevelopment of MOD sites at Foxhill and Warminster Road for mixed uses, and the Southgate shopping centre which it is proposed to redevelop primarily for retail use but including a significant residential element.  The intentions of current occupiers may be subject to some uncertainty, particularly with regard to those sites not identified in the schedule. Therefore, the estimate of housing potential of these sites may change in future studies as firmer proposals emerge.

          4. Development of under used car parks

4.9     Opportunities to release under used car parks for redevelopment are currently limited in Bath & North East Somerset and this is reflected by the fact that less than 1% of total capacity is envisaged as being derived from this source. A balance needs to be struck between redevelopment opportunities and the need to retain car parking, certainly in the short term, in order to serve the City and town centres and help to maintain their attractiveness. However, sites may come forward in this category in the longer term and this will need to be kept under review.

          5. Conversion of commercial buildings

4.10    There are few large scale vacant commercial buildings in Bath or either of the towns that would potentially be available for conversion to housing. In policy terms it is a priority to safeguard such buildings for continuing office uses, particularly in Bath City centre. 

          6. Living over the shop     

4.11    In terms of source categories 6, 7 and 8 a non-site specific approach based on analysis of overall potential and past rates of delivery has been adopted.  With regard to potential in this category analysis of data from retail surveys undertaken by the Council shows that within the three urban areas many of the retail units already have a viable use on upper floors (including significant levels of residential use).  However, some potential still exists particularly within Bath City centre and to a lesser extent the local centres.  Whilst the planning policy framework in Bath has encouraged the creation of living over the shop type accommodation, past completions appear to have been low (it is estimated that about 10 dwellings were created between 1989 and 2004).  The low number of past completions particularly in the city centre (where most of the potential exists) probably reflects the difficulty of forming a separate access for residential accommodation in city centre properties many of which are listed.  These constraints mean that despite increasing interest in city and town centre living only a limited contribution from this source is expected.

          7. Sub-division of existing housing

4.12    Some potential for sub-division of existing housing still exists, mainly within Bath where the majority of past sub-divisions have taken place.  It is considered that within the emerging planning policy context a net gain of around 12 dwellings per annum will be created from this source between 2004 and 2011.

          8. Intensification in existing housing areas

4.13    In 1999 as part of the regional study of urban housing potential, work was undertaken to divide and categorise Bath, Keynsham and Norton-Radstock into ‘typical urban areas’ on the basis of the potential for different parts of these settlements to accommodate additional housing.  This work has been utilised, as well as analysis of past building rates, in estimating housing capacity coming forward from this source.  Intensification within existing residential areas is anticipated to yield around 41 dwellings per annum, which is a similar rate to that experienced over the past 15 years, but lower than the annual average rate of completions in the eight years of the Local Plan period that have elapsed (i.e. 1996 – 2004).  As such this source will provide around 12% of the total urban housing capacity.  As detailed above (paragraph 2.4) no allowance has been made for dwellings created via the re-use of empty homes. 

5        TAKE-UP OF HOUSING CAPACITY

5.1     The market for housing in Bath & North East Somerset is strong, particularly in Bath.  Therefore, it is unlikely to act as a brake on realising the urban capacity estimated to come forward in this study.  Indeed in Bath residential land values are currently very high, thereby potentially forcing out competing but necessary uses.  These land values and their impact on the rates of housing coming forward will need to be carefully monitored and reviewed in future studies.

5.2              Monitoring of dwelling completions on urban sites since the initial study in 2000 provides an early indication of the take-up of such sites, as well as illustrating the completeness of the study in relation to source categories 1 to 5.

Table 2: Housing completions on sites within the urban areas 2000 – 2004 by source category

Source Category	Dwellings completed 2000-2004	Percentage of total completions
1.   Vacant/derelict previously      developed land and buildings	252	36.9%
2.   Vacant land not previously       developed	0	0%
3a. Redevelopment of existing housing	24	3.5%
3b. Redevelopment of other existing uses	173	25.4%
4.   Development of under used car parks	0	0%
5.   Conversion of commercial       buildings	10	1.5%
6.   Living over the shop	3	0.4%
7.   Sub-division of existing housing	23	3.4%
8.   Intensification in existing housing areas	197	28.9%
Total	682	100%

Completions

5.3     The figures in table 2 show that between 2000 and 2004 a total of 682 dwellings have been completed on sites located within the urban areas of Bath, Keynsham and Norton-Radstock. Most of these dwellings (more than 60%) were built on sites in Bath and nearly all of the dwellings came forward from three sources i.e. vacant/derelict previously developed sites, the redevelopment of existing uses (other than housing) and intensification in existing housing areas.

          Coverage of 2000 study

5.4     The monitoring of completions can provide an indication of the comprehensiveness of the study in terms of large sites assessed within source categories 1 to 5. However, with only four years of completions data available since the original study initial conclusions are tentative. Analysis shows that 459 dwellings were completed on sites falling within source categories 1 to 5 and these came forward on 25 sites. Of these 25 sites 18 (or 72%) were considered in the 2000 UHCS, accounting for 372 dwellings (around 81%) of those completed.

6          SITE INFORMATION

6.1     Details of the identified sites are shown in the attached schedule. Sites are referenced by an UHCS reference number and where appropriate the Residential Land Survey reference number is also shown. At the back of the schedule maps are included illustrating the location of the identified sites. Maps showing the boundaries of individual sites can be supplied on request. A charge will be made for such maps.

FURTHER INFORMATION

          For further information on this document please contact:

Planning Policy Team

Planning Services

Trimbridge House

Trim Street

Bath

BA1 2DP

 

Tel: 01225 – 477548

* Note: This is a draft version of the 2004 UHCS which is subject to approval for publication by the Executive Member for Sustainability and the Environment. However, it should be noted that the 2003 UHCS, which was undertaken using the same methodology and informed proposals for meeting the JRSP dwelling requirement set out in the Revised Deposit Draft of the Bath & North East Somerset Local Plan, has been approved by the Executive Member.