South Gloucestershire New Local Plan Phase 1 Responses

Local Plan 2020

List of answers to the specified question
NameResponseDate
Richard Walker - Lightwood Str… Priority 1:

Priority 1 is to ‘pursue a Carbon neutral and resilient future in changing climate.’ Our comments on Climate Change in Section 3 above suggest the Council should be adopting a methodology that ensures that the Carbon credentials of Spatial Strategy and site alternatives are measurable to enable planning judgments to be made based on insightful data.

Such a methodology will show that whatever you do to Charfield (open a railway station, with a limited service, achieving limited modal shift) or Buckover (extending MetroBus all the way out to Thornbury and hoping for some actual rather than planned on-site jobs generation) that these locations, will generate the highest of residual tailpipe Carbon emissions per trip relative to locations closer to the urban fringe of Bristol. These other locations may be in the Green Belt, but if a Climate Emergency and a 2030 target is not an exceptional circumstance to pursue a Green Belt focused strategy (due its Carbon credentials) then what is?

Due to the level of housing that the Council will need to accommodate, including meeting needs that derive from but which cannot be delivered within Bristol’s administrative area, it may be the case that less sustainable locations are needed in any case, but these should drop in at the end of the Spatial Strategy/site selection process from a Carbon reduction perspective.

Priority 6:

Priority 6 concerns housing. The Council understands that a diverse range of sites re size and locations will be needed. There is a spectrum of sustainability which guides the appropriate level of development to different places on that spectrum. The need to assess this properly and fully is acute given the Council’s declared Climate Emergency, which we assume is the overarching no.1 priority.

Providing resistance to 5-year land supply is an interesting phrase, but one that we support. We observe so many instances whereby a Plan only has one Plan (Plan A, including an initial 5% or 20% 5-year supply buffer) and if this fails to deliver then the only recourse to its correction is for the Council (or PINS) to permit sites on unallocated land or Plan review (which takes forever and is not a responsive ‘response’). Where the only sustainable supplementary land supply options left are in Green Belt then ‘lockdown,’ ensures until Plan review. Off Plan permissions don’t equate to bad development, but the LPA loses control and cumulative effects are harder to manage.

The word ‘speculative’ is used several times in the consultation document. This shows that the Council does not enjoy losing control. Embedding ‘Plan B’ sites that are the first to be released enables control to be retained if the ‘Plan A’ housing trajectory falter. Sites can be identified or have policy requirements ascribed to them, including triggers for their release. Of course, some options may currently be in the Green Belt and thus the Council would have to do more than safeguard these sites for development beyond the Plan period. They would need to be removed from the Green Belt on the adoption of the Plan. The failed High Court challenge on the Guildford Local Plan shows that LPAs can justify Green Belt release where this result is quite a large surplus against the baseline minimum need for development.
01 Jun 2021 14:01
Redcliffe Homes Please see enclosed representations. 01 Jun 2021 13:16
Robert Hitchins Ltd Please see enclosed submission.

Whilst we support the Council’s approach to optimising future development on Brownfield sites in line with pursuing an ‘Urban Lifestyles’ approach. In accordance with Paragraph 118 of the NPPF for the New Local Plan to be sound the Council’s ambition to prioritise growth in urban areas should form part of a strategy which is supplemented by the inclusion of greenfield sites which are otherwise sustainably located adjacent to existing settlements, strategic employment facilities and established transport infrastructure. The inclusion of such sites would effectively integrate new development at sustainable locations throughout the region whilst also helping to ensure the Council do not pursue an approach which is potentially over-reliant on the delivery of Brownfield sites given their associated complexities.

In addition to the above, we would also note that there could be merit in establishing clearer connections between the importance of looking at the location of new homes and new jobs within the Plan area. In this regard, Pilning is well-placed close to the Avonmouth and Severnside Enterprise Area (ASEA), which is recognised as a regionally important employment facility and as part of the recent Great Western Freeport bid (as submitted by WECA) is projected to facilitate significant economic growth throughout the region.
01 Jun 2021 12:52
Robert Hitchins Ltd and Harrow… Please see enclosed submission.

In response to Priority 6 “provide the right type and number of new homes” we would add the following comments:

• The emerging Local Plan will indeed need to meet the development requirements of the SDS including housing needs that cannot be met in Bristol. For the overall soundness of the Plan, it will also be important that the Council consider exceptional circumstances for removing land from the Green Belt in order to accommodate sustainable development.

• It is right to identify that a “portfolio” of sites will be needed. This must not include an over reliance on Brownfield sites and should recognise the need to allocate suitable greenfield land. A Green Belt review will be needed to accommodate sustainable development.

• As part of any Green Belt review it will be important to recognise that Easter Compton offers the opportunity to accommodate sustainable development and that our clients’ land does not make a significant contribution to the purposes of that designation when compared to other alternatives.
01 Jun 2021 12:24
Hannah Saunders - Dodington Pa… Page 55 – PRIORITIES:

Members would agree with the 9 priorities that have been set out to address the themes/issues discussed…. and won’t duplicate comments here.
25 May 2021 16:13
Waddeton Park Ltd - Land at Hi… 23. Yes, however as explained above, they need to be explicitly inclusive of emerging travel modes and needs and to recognise that these will be enabled by a different approach to the Spatial Strategy.

24. In addition to this, there is little mention of the need to align the Plan with strategies and plans being pursued by neighbouring Authorities, in particular Bristol, or of the cross boundary working that is essential to creating a sustainable and Carbon efficient South Gloucestershire. It is therefore suggested the Plan includes a cross boundary priority and sets out the Councils key objectives.
17 May 2021 18:40
Ivywell Capital (IC) • The decarbonisation of transport will be an important factor in achieving these goals and so it is critical that new development is located in areas with good access to services, facilities, jobs and Public Transport connections.

1. Pursue a Carbon neutral and resilient future in a changing climate.

3.2 Climate Change is rightly identified as a key issue that the Local Plan should seek to address and we are supportive of the Council's ambitions to achieve Carbon neutrality by 2030.

3.3 With regard to Housing Delivery, we agree that it is important for new development to support the de-carbonisation of transport to minimise usage of the private motor vehicle and maximise opportunities for walking and cycling. It will be imperative to locate development where access to existing or new services, facilities, employment opportunities and Public Transport are/will be strong.

3.4 Furthermore, the advent of electric vehicles and increased levels of home-working are not reasons that would justify a departure from this approach. This is because there are significant economic and social benefits to ensuring that people can access the services, facilities and jobs through a variety of means.

3.5 However, one also needs to be realistic in acknowledging individual travel patterns and behaviours will still mean additional vehicular journeys will be required. This can be mitigated by ensuring that where vehicular journeys will be made, the relative distance required to access services, facilities and employment opportunities are minimised. This would, naturally, support development at existing key settlements and areas with good access to the Bristol Urban Fringe (e.g. Tockington).

3.6 That said, maximising the potential for sustainable patterns of development will only go so far. A significant contributor to emissions is energy consumption within individual dwellings and, as a result, we also support a requirement for higher energy efficiency standards to minimise energy demand. We note that the Government has now withdrawn its intention to restrict Councils' ability to set higher energy performance standards than those prescribed in the Building Regulations. As such, we would support an approach which sought to achieve a higher standard than would otherwise be imposed at a national level.

3.7 Furthermore, the Government are still pursuing their Future Homes Standard which will require all new homes to be highly efficient with low Carbon heating and zero Carbon ready by 2025. Requiring all new homes to be Carbon neutral upon the Plan's adoption would not be such a significant step up from what will, ultimately, be the status quo moving forward and so we would support this approach.

2. Protect and enhance our environment.

3.8 The Environment is the next identified theme and, again, we are entirely supportive of the need to ensure that development leads to a betterment of the District's Biodiversity and Green Infrastructure assets and should seek to exceed identified standards where possible.

3. Development that promotes health and well-being.

3.9 Again, we are generally supportive of this priority and are committed to ensuring that high-quality open space and access to active/Public Transport routes/connections are provided.

4. Creating exceptional places and spaces.

3.10 All development should aspire to secure the highest standards of urban design and so we fully support the need for areas of growth to be legible, walkable and beautiful places to work, live and play.

5. Planning for urban and rural areas.

3.11 Naturally, we support any attempts to maximise the development potential within existing urban and rural settlements. However, we also welcome the acknowledgment that this will only go so far in meeting overall housing needs and that greenfield (whether in or beyond the Green Belt) sites will be needed to meet the development needs of the District and other WECA members. We would note that this conclusion is also reached by the Sustainability Appraisal (SA).

3.12 For reasons set out later in this document, we consider exceptional circumstances will exist to justify the removal of land from the Green Belt to support the Council's development needs. Where this is necessary, we wholeheartedly support the need to ensure that new boundaries are robust and defensible to improve its important function of restricting further urban sprawl.

3.13 We would note that the SA indicates that there will likely be significant sustainability benefits associated with the release of Green Belt land for both strategic and non-strategic levels of development and that this should be explored through the Local Plan process.

6. Provide the right type and number of new homes.

3.14 We await the progression of the West of England SDS for further details on the housing requirement that will ultimately be adopted. The only thing we would note is that the Standard Method yields a slightly higher minimum annual requirement than the adopted Core Strategy (1,360 vs 1,412 dwellings per annum).

3.15 We are also mindful that there has been a significant increase to Bristol's need following the revisions to the Standard Method (which has added around 830 dwellings to their annual requirement). Given the limited availability of land within Bristol's administrative boundary, it is unlikely that it will be able to meet its previously predicted need, let alone this increased minimum requirement itself.

3.16 Furthermore, constraints around Bath will likely limit the scope for it to accommodate some of Bristol's unmet need and so the onus will be on South Gloucestershire (and potentially North Somerset) to assist in meeting Bristol's unmet needs. As such, we would expect South Gloucestershire's minimum housing requirement be uplifted significantly from the standard method figure to account for this.

3.17 It will be important for progress to be made on the SDS and to reach a joint position with North Somerset in order to understand how housing will need to be distributed across the region and allow for effective and viable options to be considered.

3.18 We welcome the acknowledgment of the difficulties the Council has had with delivery in recent years and we would stress that the deliverability of any strategy should be a central guiding principle for the Plan. Large strategic sites will be essential to securing the overall housing requirement; however, they tend to have long lead in times, can have various complexities and often need to secure enabling infrastructure in advance of their delivery which also leads to the affordable housing provision being significantly below the adopted policy position.

3.19 The Council has had first-hand experience of this in recent years with delays to the Cribbs Patchway and East of Harry Stoke New Neighbourhoods being a key reason for their deficient housing land supply position in recent years. This has facilitated significant levels of speculative development at sites beyond the Green Belt and placed significant pressure on rural communities to make up the shortfall. Such development is not necessarily unsustainable, but it sits outside of the adopted Plan's overarching development framework which would otherwise secure a more socially, environmentally and economically sustainable outcome.

3.20 Consequently, it is imperative that the Council identify Strategic Development Locations with deliverability at the forefront of any considerations. Development locations that would require significant upfront enabling infrastructure should be carefully considered against alternative locations with less onerous requirements.

3.21 Furthermore, the Council needs to ensure that there is an appropriate balance between strategic sites and non-strategic sites to underpin delivery, particularly in the early years of the Plan period. An over-reliance on strategic sites increases the risk that housing may not come forward in a timely manner and speculative Planning Applications will be required to make up the shortfall in the context of a deficient housing land supply position. This is something the Council has stated it wishes to avoid.

3.22 Non-strategic growth will, therefore, have an important role to play in mitigating potential risks associated with delivery on strategic sites, especially in the early years of the Plan period whilst the latter make their way through the development control process.

3.23 Another important factor to consider is the relatively compressed timescale for the Local Plan and how this will affect the delivery of housing. The new Local Plan will cover a period of 15 years which is five years less than the JSP; however, the housing requirement has remained around the same level (c. 80,000 dwellings) for the WECA Authorities[1]. In simple terms, the WoE Authorities are going to have to plan for a similar amount of housing to the JSP in a shorter period of time.

3.24 This compressed timescale also means that anticipated delivery from large strategic sites over the Plan period will be reduced, especially when one factors in lead in times and applies realistic trajectories to the delivery of housing[2]. The Phase 1 document has raised the importance of ensuring that the final strategy is deliverable and any slips to delivery on identified strategic sites could have serious consequences for the Council in demonstrating a deliverable supply of housing over the longer-term.

3.25 The potential result is that a greater number of SDLs will need to be identified compared with the JSP to mitigate this risk, with the majority of these delivering housing beyond the end of the Plan period. The Local Plan will, therefore, need to take a longer-term view at this stage in the interests of ensuring the medium-term development needs of the District are met.

3.26 We would, therefore, strongly urge the Council to review alternative locations for growth and prioritise those which would require significantly less onerous infrastructure to facilitate their delivery and more realistically and reliably deliver the housing the Council needs over the Plan period.

3.27 This strategy should also be supplemented by an appropriate level of growth at the rural villages. Development at these villages is often required to ensure their vitality and viability is maintained and to ensure that important services (shops, GP Surgeries, Schools etc) are maintained. The Green Belt constraint at a number of rural villages has limited the scope for development to come forward in recent Decades and this has placed a disproportionate amount of pressure on non-Green Belt settlements (e.g. Falfield and Wickwar).

[1] Albeit the distribution is more heavily weighted toward Bristol.

[2] The often cited 'From Start to Finish' report by Lichfields should inform these assumptions.

3.28 It is also important to ensure the populations in these villages remain balanced in the interests of supporting their vitality and viability. The lack of starter homes or opportunities for downsizing in these villages mean that young people tend to move out and older people continue to occupy housing that would be more suitable for young and/or established families. Shifting demographics mean that Schools need to extend their catchments due to the need to ensure a sufficient roll of pupils can be retained to justify the School's continued operation. This is certainly the case in Olveston/Tockington where the local Primary School has had to boost its numbers by taking in students from further afield.

3.29 This is not, however, sustainable over the longer term as there are social and environmental benefits associated with children going to School close to home (closer to friends, reduced use of private motor vehicle etc). Facilitating development within these villages can help to address this imbalance.

3.30 Furthermore, the majority of the Green Belt villages are located in close proximity to important settlements or the Bristol Urban fringe. This makes them generally more sustainable locations for growth than their non-Green Belt counterparts.

3.31 Appropriate levels of growth at both Green Belt and non-Green Belt villages can help to underpin housing delivery, particularly in the early periods of the Plan period as larger strategic sites navigate their way through the planning process.

7. Enable a productive, clean and inclusive economy.

3.32 We are generally supportive of this priority and are especially supportive of the need to enhance digital connectivity across the area in light of shifting working patterns as a result of the pandemic.

8. Achieving sustainable travel and transport.

3.33 Page 47 of the Consultation Document provides a useful summary of travel to work patterns and the level of self-containment (in this context defined by the percentage of people who live and work in the same area) of certain parts of the District. What this illustrates is that not only does the North Fringe of Bristol benefit from high levels of self-containment, but also that it acts as a magnet for the wider South Gloucestershire area with significant levels of in-commuting from Avonmouth, Thornbury, Yate and the Eastern Fringe.

3.34 Locating development in close proximity/with good transport access to the Northern Fringe will be important in securing the most sustainable patterns of travel across the District.

9. Ensuring the timely and efficient provision of infrastructure to support growing communities.

3.35 We support this priority and agree that it is essential that new and growing communities are supported by an appropriate level of infrastructure to maintain and enhance their general sustainability.

3.36 The key, as we have touched on above, is ensuring that the scope and need to deliver this infrastructure does not constrain the timely delivery of housing. This can be achieved through the identification of appropriate and deliverable SDLs, which are underpinned by an appropriate level of non-strategic growth at the rural villages.
17 May 2021 15:38
Bristol and England Properties… 3.1 Yes, we are largely supportive of the priorities that have been identified. We provide individual comments on these below.

Do you have any comments on the potential priorities?

1. Pursue a Carbon neutral and resilient future in a changing climate.

3.2 Climate Change is rightly identified as a key issue that the Local Plan should seek to address and we are supportive of the Council's ambitions to achieve Carbon neutrality by 2030.

3.3 With regard to Housing Delivery, we agree that it is important for new development to support the de-carbonisation of transport to minimise usage of the private motor vehicle and maximise opportunities for walking and cycling. It will be imperative to locate development where access to existing or new services, facilities, employment opportunities and Public Transport are/will be strong.

3.4 Furthermore, the advent of electric vehicles and increased levels of home-working are not reasons that would justify a departure from this approach. This is because there are significant economic and social benefits to ensuring that people can access the services, facilities and jobs through a variety of means.

3.5 However, one also needs to be realistic in acknowledging individual travel patterns and behaviours will still mean additional vehicular journeys will be required. This can be mitigated by ensuring that where vehicular journeys will be made, the relative distance required to access services, facilities and employment opportunities are minimised. This would, naturally, support development at existing key settlements and areas with good access to the Bristol Urban Fringe (e.g. Frampton Cotterell).

3.6 That said, maximising the potential for sustainable patterns of development will only go so far. A significant contributor to emissions is energy consumption within individual dwellings and, as a result, we also support a requirement for higher energy efficiency standards to minimise energy demand. We note that the Government has now withdrawn its intention to restrict Councils' ability to set higher energy performance standards than those prescribed in the Building Regulations. As such, we would support an approach which sought to achieve a higher standard than would otherwise be imposed at a national level.

3.7 Furthermore, the Government are still pursuing their Future Homes Standard which will require all new homes to be highly efficient with low Carbon heating and zero Carbon ready by 2025. Requiring all new homes to be Carbon neutral upon the Plan's adoption would not be such a significant step up from what will, ultimately, be the status quo moving forward and so we would support this approach.

2. Protect and enhance our environment.

3.8 The Environment is the next identified theme and, again, we are entirely supportive of the need to ensure that development leads to a betterment of the District's Biodiversity and Green Infrastructure assets and should seek to exceed identified standards where possible.

3. Development that promotes health and well-being.

3.9 Again, we are generally supportive of this priority and are committed to ensuring that high-quality open space and access to active/Public Transport routes/connections are provided.

4. Creating exceptional places and spaces.

3.10 All development should aspire to secure the highest standards of urban design and so we fully support the need for areas of growth to be legible, walkable and beautiful places to work, live and play.

5. Planning for urban and rural areas.

3.11 Naturally, we support any attempts to maximise the development potential within existing urban and rural settlements. However, we also welcome the acknowledgment that this will only go so far in meeting overall housing needs and that greenfield (whether in or beyond the Green Belt) sites will be needed to meet the development needs of the District and other WECA members. We would note that this conclusion is also reached by the Sustainability Appraisal (SA).

3.12 For reasons set out later in this document, we consider exceptional circumstances will exist to justify the removal of land from the Green Belt to support the Council's development needs. Where this is necessary, we wholeheartedly support the need to ensure that new boundaries are robust and defensible to improve its important function of restricting further urban sprawl.

3.13 We would note that the SA indicates that there will likely be significant sustainability benefits associated with the release of Green Belt land for both strategic and non-strategic levels of development and that this should be explored through the Local Plan process.

6. Provide the right type and number of new homes.

3.14 We await the progression of the West of England SDS for further details on the housing requirement that will ultimately be adopted. The only thing we would note is that the Standard Method yields a slightly higher minimum annual requirement than the adopted Core Strategy (1,360 vs 1,412 dwellings per annum).

3.15 We are also mindful that there has been a significant increase to Bristol's need following the revisions to the Standard Method (which has added around 830 dwellings to their annual requirement). Given the limited availability of land within Bristol's administrative boundary, it is unlikely that it will be able to meet its previously predicted need, let alone this increased minimum requirement itself.

3.16 Furthermore, constraints around Bath will likely limit the scope for it to accommodate some of Bristol's unmet need and so the onus will be on South Gloucestershire (and potentially North Somerset) to assist in meeting Bristol's unmet needs. As such, we would expect South Gloucestershire's minimum housing requirement be uplifted significantly from the standard method figure to account for this.

3.17 It will be important for progress to be made on the SDS and to reach a joint position with North Somerset in order to understand how housing will need to be distributed across the region and allow for effective and viable options to be considered.

3.18 We welcome the acknowledgment of the difficulties the Council has had with delivery in recent years and we would stress that the deliverability of any strategy should be a central guiding principle for the Plan. Large strategic sites will be essential to securing the overall housing requirement; however, they tend to have long lead in times, can have various complexities and often need to secure enabling infrastructure in advance of their delivery which also leads to the affordable housing provision being significantly below the adopted policy position.

3.19 The Council has had first-hand experience of this in recent years with delays to the Cribbs Patchway and East of Harry Stoke New Neighbourhoods being a key reason for their deficient housing land supply position in recent years. This has facilitated significant levels of speculative development at sites beyond the Green Belt, in less sustainable locations, and placed significant pressure on rural communities to make up the shortfall. Such development is not necessarily unsustainable, but it sits outside of the adopted Plan's overarching development framework which would otherwise secure a more socially, environmentally and economically sustainable outcome.

3.20 Consequently, it is imperative that the Council identify Strategic Development Locations with deliverability at the forefront of any considerations. Development locations that would require significant upfront enabling infrastructure should be carefully considered against alternative locations with less onerous requirements.

3.21 Furthermore, the Council needs to ensure that there is an appropriate balance between strategic sites and non-strategic sites to underpin delivery, particularly in the early years of the Plan period. An over-reliance on strategic sites increases the risk that housing may not come forward in a timely manner and speculative Planning Applications will be required to make up the shortfall in the context of a deficient housing land supply position. This is something the Council has stated it wishes to avoid.

3.22 Non-strategic growth will, therefore, have an important role to play in mitigating potential risks associated with delivery on strategic sites, especially in the early years of the Plan period whilst the latter make their way through the development control process.

3.23 Another important factor to consider is the relatively compressed timescale for the Local Plan and how this will affect the delivery of housing. The new Local Plan will cover a period of 15 years which is five years less than the JSP; however, the housing requirement has remained around the same level (c. 80,000 dwellings) for the WECA Authorities[1]. In simple terms, the WoE Authorities are going to have to plan for a similar amount of housing to the JSP in a shorter period of time.

3.24 This compressed timescale also means that anticipated delivery from large strategic sites over the Plan period will be reduced, especially when one factors in lead in times and applies realistic trajectories to the delivery of housing[2]. The Phase 1 document has raised the importance of ensuring that the final strategy is deliverable and any slips to delivery on identified strategic sites could have serious consequences for the Council in demonstrating a deliverable supply of housing over the longer-term.

3.25 The potential result is that a greater number of SDLs will need to be identified compared with the JSP to mitigate this risk, with the majority of these delivering housing beyond the end of the Plan period. The Local Plan will, therefore, need to take a longer-term view at this stage in the interests of ensuring the medium-term development needs of the District are met.

3.26 We would, therefore, strongly urge the Council to review alternative locations for growth and prioritise those which would require significantly less onerous infrastructure to facilitate their delivery and more realistically and reliably deliver the housing the Council needs over the Plan period.

3.27 This strategy should also be supplemented by an appropriate level of growth at the rural villages. Development at these villages is often required to ensure their vitality and viability is maintained and to ensure that important services (shops, GP Surgeries, Schools etc) are maintained. The Green Belt constraint at a number of rural villages has limited the scope for development to come forward in recent Decades and this has placed a disproportionate amount of pressure on non-Green Belt settlements (e.g. Falfield and Wickwar).

[1] Albeit the distribution is more heavily weighted toward Bristol.

[2] The often cited 'From Start to Finish' report by Lichfields should inform these assumptions.

3.28 It is also important to ensure the populations in these villages remain balanced in the interests of supporting their vitality and viability. The lack of starter homes or opportunities for downsizing in these villages mean that young people tend to move out and older people continue to occupy housing that would be more suitable for young and established families. Shifting demographics mean that Schools need to extend their catchments due to the need to ensure a sufficient roll of pupils can be retained to justify the School's continued operation. This is certainly the case in Olveston/Tockington where the local Primary School has had to boost its numbers by taking in students from further afield.

3.29 This is not, however, sustainable over the longer term as there are social and environmental benefits associated with children going to School close to home (closer to friends, reduced use of private motor vehicle). Facilitating development within these villages can help to address this imbalance.

3.30 Furthermore, the majority of the Green Belt villages are located in close proximity to important settlements or the Bristol Urban fringe. This makes them generally more sustainable locations for growth than their non-Green Belt counterparts.

3.31 Appropriate levels of growth at both Green Belt and non-Green Belt villages can help to underpin housing delivery, particularly in the early periods of the Plan period as larger strategic sites navigate their way through the planning process.

7. Enable a productive, clean and inclusive economy.

3.32 We are generally supportive of this priority and are especially supportive of the need to enhance digital connectivity across the area in light of shifting working patterns as a result of the pandemic.

8. Achieving sustainable travel and transport.

3.33 Page 47 of the Consultation Document provides a useful summary of travel to work patterns and the level of self-containment (in this context defined by the percentage of people who live and work in the same area) of certain parts of the District. What this illustrates is that not only does the North Fringe of Bristol benefit from high levels of self-containment, but also that it acts as a magnet for the wider South Gloucestershire area with significant levels of in-commuting from Avonmouth, Thornbury, Yate and the Eastern Fringe.

3.34 Locating development in close proximity/with good transport access to the Northern Fringe will be important in securing the most sustainable patterns of travel across the District.

9. Ensuring the timely and efficient provision of infrastructure to support growing communities.

3.35 We support this priority and agree that it is essential that new and growing communities are supported by an appropriate level of infrastructure to maintain and enhance their general sustainability.

3.36 The key, as we have touched on above, is ensuring that the scope and need to deliver this infrastructure does not constrain the timely delivery of housing. This can be achieved through the identification of appropriate and deliverable SDLs, which are underpinned by an appropriate level of non-strategic growth at the rural villages.
17 May 2021 10:52
South West Housing Association… Potential Priority 6: Provide the right type and number of new homes:

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 Borough. It is important that the up-to-date definition for affordable housing is used during the production of a new evidence base for the emerging Local Plan, which may also underpin the SDS.

Given the acute affordable housing need in South Gloucestershire, we encourage the Council to set ambitious targets to increase affordable housing delivery across the Authority. Providing a separate target in the Local Plan solely for the delivery of affordable housing is a useful planning measure and should include a review mechanism to ensure that if the target is not being met that appropriate action is taken to bring forward development of more affordable housing. This should be considered alongside measures set out in the NPPF and PPG in order to be effective.
14 May 2021 19:19
Newland Homes - Land at Aust Road 1. Pursue a Carbon neutral and resilient future in a changing climate.

3.2 Climate Change is rightly identified as a key issue that the Local Plan should seek to address and we are supportive of the Council's ambitions to achieve Carbon neutrality by 2030.

3.3 With regard to Housing Delivery, we agree that it is important for new development to support the de-carbonisation of transport to minimise usage of the private motor vehicle and maximise opportunities for walking and cycling. It will be imperative to locate development where access to existing or new services, facilities, employment opportunities and Public Transport are/will be strong.

3.4 Furthermore, the advent of electric vehicles and increased levels of home-working are not reasons that would justify a significant departure from this approach. This is because there are significant economic and social benefits to ensuring that people can access the above through a variety of means.

3.5 However, one also needs to be realistic in acknowledging individual travel patterns and behaviours will still mean additional vehicular journeys will be required. This can be mitigated by ensuring that where vehicular journeys will be made, the relative distance required to access services, facilities and employment opportunities are minimised. This would, naturally, support development at existing key settlements and areas with good access to the Bristol Urban Fringe and the key Market Towns (e.g. Yate and Thornbury).

3.6 That said, maximising the potential for sustainable patterns of development will only go so far. A significant contributor to emissions is energy consumption within individual dwellings and, as a result, we also support a requirement for higher energy efficiency standards to minimise energy demand. We note that the Government has now withdrawn its intention to restrict Councils' ability to set higher energy performance standards than those prescribed in the Building Regulations. As such, we would support an approach which sought to achieve a higher standard than would otherwise be imposed at a national level.

3.7 Furthermore, the Government are still pursuing their Future Homes Standard which will require all new homes to be highly efficient with low Carbon heating and zero Carbon ready by 2025. Requiring all new homes to be Carbon neutral upon the Plan's adoption would not be such a significant step up from what will, ultimately, be the status quo moving forward and so we would support this approach.

2. Protect and enhance our environment.

3.8 The Environment is the next identified theme and, again, we are entirely supportive of the need to ensure that development leads to a betterment of the District's Biodiversity and Green Infrastructure assets and should seek to exceed identified standards where possible.

3. Development that promotes health and well-being.

3.9 Again, we are generally supportive of this priority and are committed to ensuring that high-quality open space and access to active/Public Transport routes/connections are provided.

4. Creating exceptional places and spaces.

3.10 All development should aspire to secure the highest standards of urban design and so we fully support the need for areas of growth to be legible, walkable and beautiful places to work, live and play.

5. Planning for urban and rural areas.

3.11 Naturally, we support any attempts to maximise the development potential within existing urban and rural settlements. However, we also welcome the acknowledgment that this will only go so far in meeting overall housing needs and that greenfield sites will be needed to meet the development needs of the District and other WECA members. We would note that this conclusion is also reached by the Sustainability Appraisal (SA).

3.12 For reasons set out later in this document, we consider exceptional circumstances will exist to justify the removal of land from the Green Belt to support the Council's development needs. Where this is necessary, we wholeheartedly support the need to ensure that new boundaries are robust and defensible to improve its important function of restricting further urban sprawl.

3.13 We would note that the SA indicates that there will likely be significant sustainability benefits associated with the release of Green Belt land for both strategic and non-strategic levels of development and that this should be explored through the Local Plan process.

6. Provide the right type and number of new homes.

3.14 We await the progression of the West of England SDS for further details on the housing requirement that will ultimately be adopted. The only thing we would note is that the Standard Method yields a slightly higher minimum annual requirement than the adopted Core Strategy (1,360 vs 1,412 dwellings per annum).

3.15 We are also mindful that there has been a significant increase to Bristol's need following the revisions to the Standard Method (which has added around 830 dwellings to their annual requirement). Given the limited availability of land within Bristol's administrative boundary, it is unlikely that it will be able to meet its previously predicted need, let alone this increased minimum requirement itself.

3.16 Furthermore, constraints around Bath will likely limit the scope for it to accommodate some of Bristol's unmet need and so the onus will be on South Gloucestershire (and potentially North Somerset) to assist in meeting Bristol's unmet needs. As such, we would expect South Gloucestershire's minimum housing requirement be uplifted significantly from the standard method figure to account for this.

3.17 It will be important for progress to be made on the SDS and to reach a joint position with North Somerset in order to understand how housing will need to be distributed across the region and allow for effective and viable options to be considered.

3.18 We welcome the acknowledgment of the difficulties the Council has had with delivery in recent years and we would stress that the deliverability of any strategy should be a central guiding principle for the Plan. Large strategic sites will be essential to securing the overall housing requirement; however, they tend to have long lead in times, can have various complexities and often need to secure enabling infrastructure in advance of their delivery.

3.19 The Council has had first-hand experience of this in recent years with delays to the Cribbs Patchway and East of Harry Stoke New Neighbourhoods being a key reason for their deficient housing land supply position. This has facilitated significant levels of speculative development at settlements beyond the Green Belt and placed significant pressure on rural communities to make up the shortfall. Such development is not necessarily unsustainable, but it sits outside of the adopted Plan's overarching development framework which would otherwise secure a more socially, environmentally and economically sustainable outcome.

3.20 Consequently, it is imperative that the Council identify Strategic Development Locations with deliverability at the forefront of any considerations. Development locations that would require significant upfront enabling infrastructure should be carefully considered against alternative locations with less onerous requirements.

3.21 Another important factor to consider is the relatively compressed timescale for the Local Plan and how this will affect the delivery of housing. The new Local Plan will cover a period of 15 years which is five years less than the JSP; however, the housing requirement has remained around the same level (c. 80,000 dwellings) for the WECA Authorities[1]. In simple terms, the WoE Authorities are going to have to plan for a similar amount of housing to the JSP in a shorter period of time.

3.22 This compressed timescale also means that anticipated delivery from large strategic sites over the Plan period will be reduced, especially when one factors in lead in times and applies realistic trajectories to the delivery of housing[2]. The Phase 1 document has raised the importance of ensuring that the final strategy is deliverable and any slips to delivery on identified strategic sites could have serious consequences for the Council in demonstrating a deliverable supply of housing over the longer-term.

[1] Albeit the distribution is more heavily weighted toward Bristol.

[2] The often cited 'From Start to Finish' report by Lichfields should inform these assumptions.

3.23 The potential result is that a greater number of SDLs will need to be identified compared with the JSP to mitigate this risk, with a proportion of these delivering housing beyond the end of the Plan period. The Local Plan will, therefore, need to take a longer-term view at this stage in the interests of ensuring the medium-term development needs of the District are met.

3.24 We would, therefore, strongly urge the Council to review alternative locations for growth and prioritise those which would require significantly less onerous infrastructure to facilitate their delivery and more realistically and reliably deliver the housing the Council needs over the Plan period.

3.25 This strategy should also be supplemented by an appropriate level of growth at the rural villages. Development at these villages is often required to ensure their vitality and viability is maintained and to ensure that important services (shops, GP Surgeries, Schools etc) are not lost. The Green Belt constraint at a number of rural villages has limited the scope for development to come forward in recent Decades and this has placed a disproportionate amount of pressure on non-Green Belt settlements, especially in the context of a deficient housing land supply position (e.g. Falfield and Wickwar).

3.26 Furthermore, the majority of the Green Belt villages are located in close proximity to important settlements or the Bristol Urban fringe. This makes them generally more sustainable locations for growth than their non-Green Belt counterparts.

3.27 Appropriate levels of growth at both Green Belt and non-Green Belt villages can help to underpin housing delivery, particularly in the early periods of the Plan period as larger strategic sites navigate their way through the planning process.

7. Enable a productive, clean and inclusive economy.

3.28 We are generally supportive of this priority and are especially supportive of the need to enhance digital connectivity across the area in light of shifting working patterns as a result of the pandemic.

8. Achieving sustainable travel and transport.

3.29 Page 47 of the Consultation Document provides a useful summary of travel to work patterns and the level of self-containment (in this context defined by the percentage of people who live and work in the same area) of certain parts of the District. What this illustrates is that not only does the North Fringe of Bristol benefit from high levels of self-containment, but also that it acts as a magnet for the wider South Gloucestershire area with significant levels of in-commuting from Avonmouth, Thornbury, Yate and the Eastern Fringe.

3.30 Locating development in close proximity/with good transport access to the Northern Fringe will be important in securing the most sustainable patterns of travel across the District.

9. Ensuring the timely and efficient provision of infrastructure to support growing communities.

3.31 We support this priority and agree that it is essential that new and growing communities are supported by an appropriate level of infrastructure to maintain and enhance their general sustainability.

3.32 The key, as we have touched on above, is ensuring that the scope and need to deliver this infrastructure does not constrain the timely delivery of housing. This can be achieved through the identification of appropriate and deliverable SDLs which are underpinned by an appropriate level of non-strategic growth at the rural villages.
14 May 2021 17:12
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