South Gloucestershire New Local Plan Phase 1 Responses

Local Plan 2020

List of answers to the specified question
Richard Walker - Lightwood Str… Comments below relate to Question 2: Issues:

Please see the attached representations document and appendices.

The representations are presented in four parts.

• Part 1 addresses on the Phase 1: Issues and Approaches consultation. This is formatted to enable ease of reference to the relevant section of the consultation document.

• Part 2 addresses the Sustainable Access Profiles (Methodology and the outputs for Shortwood).

• Part 2 addresses the Sustainability Appraisal Framework.

• Part 4 provides additional information and appendices to supplement our October 2020 Call for Sites’ submission in October 2020.

o Appendix 1: Agricultural land survey (web link to Natural England website within Section 4).

o Appendix 2: Terradat Report on Ground Conditions.

o Appendix 3: Urban Design and Masterplanning.

 Sheet 1: Growth on Bristol’s Eastern Edge – Strategic Context.

 Sheet 2: Growth on Bristol’s Eastern Edge – Context within 1km.

 Sheet 3: Illustrative Masterplan.

 Sheet 4: 3D sketch Main Road.

 Sheet 5: 3D sketch Rock House Green.

One cover has been suppled in respect of our comments on all:

• The Phase 1 Issues and Approaches document.

• The Access Profiles.

• The SA (November 2020).
01 Jun 2021 14:01
Redcliffe Homes Please see enclosed representations. 01 Jun 2021 13:16
Robert Hitchins Ltd Please see enclosed submission.

We broadly support the Council’s identification of the respective issues subject to addressing the comments as set out below.

Furthermore, for the New Local Plan to be ‘sound’ the Council will need to ensure the Plan is positively prepared (in line with Paragraph 16 of the NPPF) by establishing a strategy which not simply meets the needs of South Gloucestershire’s administrative area but can also accommodate proportionate levels of unmet need arising from Bristol in sustainable locations. On that note we recognise that the consultation document does not make reference to the fact that Bristol’s standard methodology figure equates to 3,196 homes per annum, which represents a 142% increase of Bristol City Council’s current Local Plan requirement. Given the city’s spatial constraints it is unfeasible to think that this level of growth will be accommodated within the administrative area of Bristol and subsequently it is inevitable that South Gloucestershire will be required to take up an appropriate proportion of this unmet need. As a result of the above, we do not believe that the consultation document goes far enough in acknowledging the role South Gloucestershire will need to play in accommodating Bristol’s unmet needs. As part of any Spatial Strategy, we would continue to stress the importance of not only prioritising future development within existing urban areas, but the vital role sustainable rural villages can provide in contributing towards a sustainable pattern of development.

The Council highlights the necessity to undertake a “regional Employment Land and Spatial Needs Assessment (ELSNA)” together with an “Employment Land Review” to establish the quality and quantity of existing and future employment land throughout the Authority’s administrative area. Whilst we support this pragmatic approach, to ensure the soundness for the New Local Plan it is imperative that this work is carried out in accordance with the guidance as defined within the National Planning Policy Framework (NPPF). We would similarly continue to emphasise our support and encouragement for the Council to progress such work as soon as possible in order to establish a robust evidence base early on during the Plan making process. The merits associated with which will enable any future strategy to be underpinned by a reputable source of information to deliver the economic ambitions of the West of England whilst also capitalising on significant opportunities for future growth in key strategic locations including the Avonmouth & Servernside Enterprise Area (ASEA) and proposed Great Western Freeport area.

In light of the above, whilst we recognise the Council’s priority to protect and optimise employment provision on existing sites it is important for the local economy that new employment land is identified, allocated and subsequently comes forward over the proposed Plan period. Understandably the sustainability criteria of respective sites will be tested at a future stage however it will be important that the sites complement existing strategic employment provision (such as the ASEA) and are well-served by supporting infrastructure including direct connections on to the strategic highway and national rail networks.

Whilst the Council correctly focus on the need to make efficient use of previously developed land, this should not be at the expense of deliverability or creating unsustainable patterns of development and nor should it potentially result in restraining the economy through the loss of employment land within existing urban areas. Consequently, we would suggest greater emphasis needs to be attached to avoiding the potential loss of employment land within the defined urban area and the unintended consequences associated with urban intensification.

The accompanying Sustainability Appraisal states that within the context of South Gloucestershire a key consideration remains there is a “Lack of suitable land remaining within existing settlement limits for development which causes additional growth pressures in urban areas. This needs to be balanced with achieving a high quality of life and safeguarding our built and natural assets in urban locations” (Page 31). Consequently, we would suggest there would be significant benefits of undertaking an ‘urban capacity’ exercise to initially establish the scale of change anticipated within existing urban areas. Furthermore, this would enable the Authority to provide greater certainty on the quantum of new development envisaged over the Plan period whilst simultaneously allowing a more informed opinion to be made regarding the overarching balance between Brownfield, greenfield and Green Belt land. To achieve a sustainable pattern of development we believe that the New Local Plan should include a range of different sites across the Authority as part of the proposed strategy with a more diverse portfolio of sites to contribute towards a more resilient 5-Year Housing Land Supply.
01 Jun 2021 12:52
Robert Hitchins Ltd and Harrow… Please see enclosed submission.

Whilst the Council has recognised a number of pertinent issues, we would continue to highlight the importance of any Spatial Strategy remaining flexible in order to accommodate suitable levels of future growth as expected to be set out through the West of England Combined Authority (WECA) Spatial Development Strategy (SDS). As part of the current planning system, and in accordance with Paragraph 24 of the National Planning Policy Framework (NPPF) “Local Planning Authorities and County Councils (in two-tier areas) are under a Duty to Co-operate with each other, and with prescribed bodies, on strategic matters that cross administrative boundaries.” Moreover, for the new Local Plan to be ‘sound’ South Gloucestershire Council will need to ensure the Plan is positively prepared by establishing a strategy which not only seeks to meet the objectively assessed needs of the region itself but can also accommodate an appropriate proportion of Bristol’s unmet need over the Plan period.

Issue 22 seeks to increase development in urban areas. Whilst the principle of optimising previously developed land is supported, the Council rightly recognises that the quantum of such sites may be constrained and as such it will be important for the Council to demonstrate the viability of those sites within the urban area that will be expected to come forward over the proposed Plan period.
01 Jun 2021 12:24
Hannah Saunders - Dodington Pa… • Members agree that the right themes (9) and accompanying issues (55) are the right ones for the new Local Plan to be considering.

Page 23 – Travel and accessibility:

• It is felt that one of the main barriers to cycling connectivity around our area (in particular Yate/Sodbury into Bristol) is the lack of finance and low prioritisation by South Gloucestershire Council. There are cycle paths and schemes – but not all join up and this will need to be addressed if cycling is to be encouraged.

• The high level of car ownership and use is down to fact that in a lot of the outlying rural areas there is little or no bus service. It will be mentioned later in comments but Members feel that rural areas should be more connected to centres where there are transport hubs – and this could be by small buses that run at sensible intervals to and from the hubs.

• Yate, Sodbury and Dodington has a network of walkways and links but would like to see these better signposted and marked (similar to Bradley Stoke if you are looking for a local example) or if you are looking for something different – Bicester Blue Line Project.

Page 27 – Climate Change:

• Members would comment that the move towards decarbonising transport may be hindered by opposition to cycle lanes and the reduced capacity of Public Transport during COVID. COVID restrictions over the past year have pushed people towards private motorised transport – and also they have been encouraged NOT to car share…. so more cars on road potentially.

Page 28 – 31 – Environment:

• Members strongly support all of the items/strategies mentioned here – in particular the ‘Connecting & Enhancing Wildlife Habitats’ and ‘Green Infrastructure Strategies.’

• With regards to ‘Tree loss and Provision’ Members recognise that it is important – but doubling the tree canopy cover will need land allocated to it. How will SGC go about this? Right trees have got to be planted in the Right places.

• Members would also point out that by repurposing agricultural land, Food Miles could be increased – and this wouldn’t help with Carbon reduction.

Page 32 – Health and Well Being:

• Members strongly support ‘Opportunities for physical activity,’ the importance of this has been highlighted over the past year with lockdown and Covid-19.

• With regards to ‘Accessible health services and facilities’ Members are extremely concerned that Abbotswood GP Surgery is currently NOT providing most services within our local area –patients are expected to travel miles to other Surgeries in the Practice (Emersons Green and Downend). With the growth of North Yate and area…. we have MIU – but it is felt that Hospital provision should be considered – Members understand that this isn’t the remit of the Local Plan – but would strongly recommend that comment is forwarded to Clinical Commisioning Group....CCG…. something like the Vale Hospital in Dursley…. with the Yate Town Improvement Masterplan – surely this is something that could be considered? It would have a knock on effect and help with ‘Health issues and inequalities.’

• With regards the ‘Takeaways and Schools’…. this is taking the icecream vans outside Schools to the next step, and Members really don’t agree with this issue. They feel it goes a lot deeper than this – and is about education. It feels like SGC is just ticking a box with this one and has not put enough thought into the matter. Members agree if people get into healthy habits at a young age – then this continues into adulthood…. it is felt the bigger picture with regards childhood obesity needs to be addressed.

Page 34 – Exceptional Places:

• Members are concerned about the statement ‘Optimising density and walkable neighbourhoods’…. they would like reassurance that developers won’t read optimising density means increasing density…. as this comes at a cost in terms of standards of living environment. Agree need to find the balance…. between housing density and outdoor space, etc…. and need to state that ‘less is more’…. see below.

• Less dense developments are more permeable and hence more walkable – the opposite of what the statement suggests – denser developments may have apparent shorter distances to facilities as the crow flies, but getting to them is often a circuitous and less pleasant route.
(see comments on Normandy Drive pages 75 - 90)

Page 35 – Planning for Rural and Urban Areas:

• Members agree with all of these issues….

Page 38 – Plannning for New Homes:

• Members agree and support the need for ‘Homes to meet needs of elderly’ and this isn’t necessarily sheltered accommodation…. it allows them to downsize whilst staying in same area.

• ‘Housing affordability,’ Members strongly support true affordability of new homes based on local incomes, they do not support basing “affordability” on local house prices and rents because these reflect artificial historic inflation due to previous unrealistic “affordability policies.”

• ‘Planning for different groups’ Members strongly support diverse housing to reflect differing needs, too much of the existing housing stock is very similar, there is little diversity.

• ‘Gypsy/traveller and travelling showmen communities’ Members would comment that the number of temporary encampments in recent years demonstrates a longstanding shortfall in traveller transit sites – new sites are needed.

• ‘Five year housing land supply’ Members feel that the Council and other public Authorities may need to consider how it can lead and facilitate land assembly and infrastructure delivery – Infrastructure delivery is key, and should be a must not a maybe.

Page 42 – Our Economy:

• Members recognise there is a ‘Change/Challenge for town centres and High Streets’ Covid-19 has just added to this. As mentioned previously Members have engaged extensively with the Yate Town Masterplan Improvement.

• With regards to issues 36 – 40…. Members know that more employment is needed local to Yate and Chipping Sodbury. Although the proposed numbers and locations of housing will doubtless be the “headline” in public discussions, the locations and types of employment will be extremely important.

• Much of the existing employment is minimum wage, particularly in the services sector, and typically jobs that cannot be done from home. A greater variety of higher skilled and well paid jobs is needed in this area to stop people commuting out or moving away (this is a significant reason why we are seeing an ageing population).

• We have poor Public Transport links except from Yate and Chipping Sodbury into Central Bristol, limiting employment opportunities except for people who can drive or can afford to drive.

• This feeds through into low aspirations in terms of employment and education, with lower than expected numbers of local young people entering post-18 education and training. This perpetuates the long-standing situation as evidenced by the statistics behind the multiple deprivation indices in our Priority Neighbourhoods.

Page 47 – Travel and Transport:

• Members understand that the Travel to Work data used is from a 2011 Census. Housing developments and employment patterns have changed travel patterns appreciably since that time, and current data is essential for forward planning.

• With regards ‘Decarbonising Transport’ Members feel that LA should engage with future employers – so that they look at buses to get staff in, car pools, car share. Ensure they have showers and changing facilities for those that may walk/cycle. Staggered starts – to allow for dropping children at School and then getting in. Home working part of the week.

• ‘Walkable Neighbourhoods – Urban’ Members agree that residents in our Parish (urban part) can use bus/train to get elsewhere…. or walk/cycle within the area…. BUT the walking routes need to be better signposted (as mentioned previously) and the cycle routes need joining up.

• ‘Walkable Neighbourhoods – Rural’ Members would comment that if you live in a rural community you can not currently get to a transport hub to get to other urban areas easily…. as such you have to drive – but parking restrictions at these hubs do not allow long enough stays or are not available – meaning you end up having to rely on car and drive all way…. this doesn’t help with issue 41 ‘Decarbonising Transport.’ As stated previously rural areas need to be better connected.

• ‘Transport Infrastructure’ Members would agree that there has been investment – but – need to see MetroBus come out as far as Yate and Chipping Sodbury…. plus need to join up cycle routes and a two way Park and Ride.

Page 50 – Supporting Infrastructure:

• Members would hope that SGC have learnt from past mistakes and that infrastructure comes at the same time as the development.

• ‘Broadband & Digital Connectivity’ Covid-19 has highlighted this further, in future we will see more people working from home, some students may be doing more by distance learning. In rural communities farmers rely on Internet now…. so it is key that we get this right – and ensure that people are digitally connected.

• ‘Drainage & Sewerage’ Members would point out that some of our systems are now at capacity…. any additional development should take this into consideration.

• ‘Community Centres’ Members would comment that Dodington Parish Hall is now running at capacity – ideally they need to expand…. with ageing community in our area – we are going to see a greater demand on these facilities…. Covid-19 too has shown the need for hubs such as this….

• ‘Sport & Recreation’ Members strongly support that this should be freely available to all.

• ‘Doctors/GP’s’ Members would point out the issues locally with Abbotswood Surgery where residents are forced into making difficult journeys either by Public Transport or car. In all future Planning need to ensure that this sort of thing doesn’t happen again.
25 May 2021 16:13
Waddeton Park Ltd - Land at Hi… 14. South Gloucestershire Council (SGC) has identified a wide range of issues that it would like to consider, and it is clear this Plan is intended to be guided by a response to Climate Change, the mitigation of it, and building in future resilience. Our client supports this approach and the wide range of issues that the Plan is seeking to provide policy guidance on.

15. However, whilst these issues and priorities are generally wide ranging, there is some concern that the Plan is missing the need to align its Spatial Strategy with cross-boundary issues arising from its neighbouring Authorities, including Bristol City and the consequences of placing development in the right location to address Climate Change and the need for South Gloucestershire residents to work in the City.

16. It is well known that Bristol City has a very significant influence on SGC and especially travel, employment, and housing. This specific influence can be summarised as:

 The movement of people to and from Bristol City for work, leisure and commerce.

 The impact of the Bristol economy on the wealth and resilience of SGC’s population given a proportion of this is generated by those who work in the City.

 The impact of housing those who wish to live and work in Bristol, but whose needs must be met in South Gloucestershire due to land availability constraints.

17. There is clear evidence that SGC will need to accommodate some of Bristol’s housing and economic needs within their administrative boundaries during the Plan period and positive steps have been made to prepare a Memorandum of Understanding through the WECA framework. A structure for responding to this however, seems to be missing from SGC’s proposed part 1 approach to Plan-making? The latest Standard Method calculation which places a significant uplift on Bristol’s housing need increases the immediate pressure that will form part of the SGC and other Local Plan Spatial Strategies. It is therefore suggested at the very least a SoCG should be prepared with the WECA Authorities to guide this Part 1 Plan as well as the subsequent Part 2 Plan.

18. Whist the withdrawal of the JSP has caused a delay in addressing the effects of cross boundary growth, it is essential that it responds to the impact of travel to Bristol and aligns with Climate Change objectives. Whilst the over-arching Mayoral SDS is yet to be published in draft, the emerging SGC Part 1 Plan needs to make provision in the suggested policies to accommodate this strategy.

19. A sound Part 1 Plan should make provision for cross-boundary growth now and recognise the inter-relationship between Bristol and its urban fringes and nearby settlements within South Gloucestershire.

20. In summary, addressing the inter-relationship between South Gloucestershire and Bristol should be one of the Issues and Priorities.

21. Waddeton Park Ltd also support the notion of walkable neighbourhoods. What the Plan must not lose sight of is the recent and accelerating change in travel patterns and modes and in particular, the growing use and planning for e-bikes and e-scooters as a means of travel. These offer a greater range of movement than the walkable neighbourhood especially for employment related trips but are reliant on high quality cycle routes which connect wider areas than the 10-minute walkable neighbourhood. The Spatial Strategy does not recognise the role of this transport mode at present or other future mobility whose delivery will be accelerated during the Plan period.

22. It is suggested that the Issues and Priorities should include how the Plan encourages new types of modal shift to enable convenient e-bike and e-scooter use and identify reasonable travel distances. E-bikes will enable rapid and convenient movement between the Urban Fringes of Bristol and the Centre, as well as from the larger villages closest to the Fringe where there is very convenient access to a dedicated wider cycle network.
17 May 2021 18:40
Ivywell Capital (IC) • We are broadly supportive of the Council's identified issues and priorities especially the need to help combat the impacts of Climate Change whilst sustainably meeting the development needs of the District which will ultimately be set out in the SDS. The significant increase to Bristol's housing need under the new Standard Method, coupled with constraints on development both at Bristol and Bath means that South Gloucestershire will likely need to accommodate growth significantly in excess of the Standard Method figure to deliver the region's housing requirement.

2.2 For the sake of brevity, we have not commented on every individual identified issue; however, we are broadly supportive of those that have been identified. We have provided more detailed comments on the 9 priorities which have effectively been borne out of the key issues that have been identified.

Would you like to comment on any of the issues or add new issues?

2.3 The issues identified within the Phase 1 document cover those relevant to our client's interest and so we have no further comments to make.
17 May 2021 15:38
Bristol and England Properties… We are broadly supportive of those that have been identified. We have provided more detailed comments on the 9 priorities which have effectively been borne out of the key issues that have been identified.

Would you like to comment on any of the issues or add new issues?

2.3 The issues identified within the Phase 1 document cover those relevant to our client's interest and so we have no further comments to make.
17 May 2021 10:52
South West Housing Association… Key Issues:

1: Climate Change:

Climate Change is high on the Government’s agenda with the national target of net zero Carbon emissions by 2050. Therefore, we support the Council’s commitment to be Carbon neutral by 2030. As Housing Associations we recognise the critical role that we play in ensuring that residents have safe, secure and efficient homes that are future proof. Promoting sustainable development is the core objective of the planning system and it is important all new developments continue to support this aim.

We comment further on Climate Change and potential viability implications in our response to Appendix 2.

19: inclusive design:

The HAPC supports the Council’s view that affordable housing should be distributed throughout development and provided in a tenure blind manner in order to create diverse, mixed and well-balanced communities.

The distribution of affordable housing within housing schemes should allow for social integration within the overall design but should also consider the practical implications for Housing Associations when it comes to the management of their housing stock. Encouraging pepper potting across a scheme makes management more difficult as the properties are more spread out. We would recommend that affordable housing is clustered across a site, with policy expressing a maximum group size or range; 10 to 15 dwellings forming each cluster on larger sites is commonly favoured.

26: Growth in rural villages and settlements:

We encourage the Council to consider reviewing its settlement boundaries and look to allocate sites for development in its smaller settlements. Well-planned housing growth in rural areas can provide market and much needed affordable housing alongside new employment opportunities and improved infrastructure which is all needed in order to sustain existing local services and facilities in rural communities and make rural housing more affordable for younger generations.

Exception sites (both rural and entry-level) have been widely welcomed as an addition to the opportunities Housing Associations have to meet housing needs in areas that may not otherwise have been considered suitable for general housing proposals. Both policy tools enable the delivery of affordable housing to meet identified need in rural areas, particularly when allowing the cross-subsidy of these sites with an element of market housing in order to facilitate affordable housing delivery.

We would like to use this opportunity to highlight the successful proven track record that Community Land Trusts (CLTs) have in delivering affordable housing for local people, particularly in rural areas. The Council may find it insightful to know that a number of the HAPC members have delivered significant levels of affordable housing through partnerships with CLTs across the South West of England. Therefore, it would be useful if the Local Plan acknowledges this working relationship in order to encourage commitment in the Local Plans to support CLTs in their choice of sites.

It is therefore right that the Council acknowledges that it will need to consider the future growth of rural villages and settlements as part of the Local Plan review.

29: Housing affordability:

The Council recognise that despite its efforts in improving affordable housing delivery in recent years, affordability remains a persistent problem in the Authority. Significantly more market and affordable housing needs is required in order to alleviate the affordability issue. As the affordability crisis continues, with many households priced out of homeownership, Housing Associations have a vital role in providing much needed affordable homes for the community.

The Local Plan should seek to drive change across the Authority through a pragmatic and ambitious approach to affordable housing, encouraging greater diversity to meet all needs. We strongly encourage the Council to set ambitious targets for affordable housing as a mechanism to significantly increase delivery and improve affordability across the Authority.

Footnote 16 on page 40 of the consultation document defines affordable housing as social, rented and intermediate tenures. This footnote should be updated so that it refers to the up-to-date definition for affordable housing at Annex 2 of the NPPF. Incorporating the wider definition of affordable tenures at Annex 2 of the NPPF will be important in ensuring consistency with the Framework and will enable the delivery of such tenures in South Gloucestershire.

30: Planning for different groups:

The revised NPPF (2019) introduced significant changes in how the Council will look to assess the need for affordable housing, including the size, type and mix of affordable housing to meet local needs within different areas of the District. We understand that a new evidence will be commissioned, and it is likely that WECA will co-ordinate the local housing needs for its constituent Authorities in partnership with North Somerset Council. Matters that should be thoroughly explored by a new evidence base include the following:

• Thoroughly and objectively assess the need of all types of affordable housing, referring to NPPF Annex 2 for the national definition;

• Makes it clear that private rented housing does not constitute a valid substitute for affordable housing and should not be allowed for in any affordable housing figure;

• Includes the objectively assessed need for the housing requirements of older people;

• Take full account of market signals. With the Planning for the Future proposals and the effects of COVID-19 on the housing market, any local housing needs assessment should fully consider the effect these may have on the market, especially if population and migration figures are being based on trends set in an economic recession;

• Ensures any housing figure is based on aspirational economic projections.

We look forward to reviewing the evidence base when it becomes available and will be responding to future WECA consultations.
14 May 2021 19:19
Newland Homes - Land at Aust Road 2.2 For the sake of brevity, we have not commented on every individual identified issue; however, we are broadly supportive of those that have been identified. 14 May 2021 17:12
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