South Gloucestershire New Local Plan Phase 1 Responses

Local Plan 2020

List of answers to the specified question
NameResponseDate
Richard Walker - Lightwood Str… We are pleased to see recognition that, in-principle, small urban extensions (as well as large ones) provide a credible option for the growth of the main urban areas of the North and East Fringe. All reasonable options adjoining the North and East Fringe, of all sizes, need to be considered and evaluated. Due to the presence of the M4 and M5, urban extension options to the main urban areas beyond these barriers will need to achieve a critical mass to be able to demonstrate place-making credentials. Consequently, Green Belt land take would be significant in such locations.

Options beyond the A4174, which, in places, is not such a barrier to movement into the North East Fringe, can credibly offer slinked smaller (or larger) urban extension options and quality placemaking.

The Council is clearly aware of the pitfalls of relying on a small number of very large sites, which presenting various degrees of complexity (as set out in Key Issues 32 and 33). Whilst stepped trajectories can be justified where several large sites with infrastructure prerequisites are needed, this ‘stepping’ should not be at the expense of the allocation of more deliverable i.e. non-strategic sites that can deliver housing sooner in the Plan period. Rock House Farm, Shortwood is one such example. The Examination of the St. Albans Local Plan (now withdrawn) and the Inspectors' April 2020 letter identifies that it is high risk to over rely on a few strategic sites in terms of (1) the need of an overly steeped delivery trajectory and (2) overlooking a suite of small-medium sized sustainable extensions (100 - 300 homes) with less Green Belt impact.

At present the definition of scale when reading across Blocks 2, 4 and Section 7 is not clear. Our inclination is that small/medium is being used in a relative sense within Building Block 4, not an absolute one.

As the Plan progresses Council needs to be clear if its scale bar in respect of small or medium scale development rural settlements is being used in relative terms or absolute terms, and this follows through into Section 7. At present our reading of Section 7 is that medium scale, in that, context is being used in relative terms.
01 Jun 2021 14:01
Redcliffe Homes Please see enclosed representations.

2.4 There are a range of different types of settlements across South Gloucestershire, and therefore a vast array of issues to address which in our view could not be solved through the adoption of one specific ‘Building Block’ as a Spatial Strategy. It is our view that a blend of the Building Blocks should be put forward to address the different key priorities and issues raised within the consultation document, with a significant proportion of land being allocated on the edge of Bristol, followed by Market Towns, with rural towns and villages receiving a proportion of need to address their individual concerns (for example, sustaining local facilities, bringing in investment via CIL to local Parish Councils to spend on local infrastructure projects, and addressing surplus capacity available in Primary Schools).

2.5 We do not agree with the principle of allocating a new freestanding settlement if this involves land at Buckover, or anywhere in the Northern periphery of South Gloucestershire, being pursued as a development option. We have set out on many occasions within our representations to the JSP why we did not agree with such an approach and how it scored very poorly in terms of sustainability assessment. The problems associated with such a strategy primarily relate to the impact this will have on Carbon emissions and air quality as it will result in residents travelling South to work in Bristol; and the infrastructure funding gap that was identified within the evidence base to the JSP as a result of needing to significantly extend the MetroBus infrastructure to the North.

2.6 We therefore consider that a ‘blend’ of Building Blocks will be required to meet the needs of South Gloucestershire and unmet need from Bristol, which will include a review of Green Belt land and release for large scale allocation, followed by a proportionate level of development on the edge of Market Towns and Rural Villages/Settlements, such as Old Sodbury.
01 Jun 2021 13:16
Robert Hitchins Ltd Please see enclosed submission. 01 Jun 2021 12:52
Robert Hitchins Ltd and Harrow… Please see enclosed submission.

We broadly support the five Building Blocks identified by South Gloucestershire Council which are helpful in illustrating the options available. In reality more than one option may well be needed to meet the development needs of South Gloucestershire. To ensure the soundness of the emerging Local Plan we would continue to emphasise the importance of providing a diverse portfolio of sites in a range of sustainable locations to accommodate growth across the region. The sustainability credentials of future sites will inevitably be subject to further consideration as the process continues, however proximity to the existing urban area of Bristol, connectivity to strategic employment provision and accessibility to transport infrastructure should form essential factors to achieve more sustainable patterns of development. We would anticipate the Spatial Strategy being informed by a combination of all respective Building Blocks.
01 Jun 2021 12:24
Hannah Saunders - Dodington Pa… Page 60 – STRATEGY:

• ‘Potential Urban Lifestyle Locations’…. the Yate area forms one of these – and Members will repeat what they have said before – when talking about optimising density SGC need to make clear that this isn’t about increasing density….
25 May 2021 16:13
Waddeton Park Ltd - Land at Hi… 25. The 5 categories identify all the different spatial approaches for accommodating development. As such they represent a consistent approach with National Planning Policy. However, there is concern that categories 1 - 5 could represent some form of sequential approach which would be inappropriate. Given the character and structure of settlements in South Gloucestershire it is not always going to be the case that the Urban Lifestyle Living will generate the most sustainable form of development or that it will represent the best response to Climate Change when travel patterns are fully considered. Further consideration should be given to development proposals, that are sustainably located to meet several National and Regional objectives. Appendix 2 provides a technical assessment of why this is the case in respect of Winterbourne when compared to the most sustainable settlements outside the Green Belt.

26. It is inevitable that a proportion of residents from across South Gloucestershire will travel to a range of destinations within Greater Bristol and as such places like Thornbury, Chipping Sodbury and Yate, which form part of the Potential Urban Lifestyle locations will generate longer car borne trips than other settlements close to Bristol. Evidence set out in Appendix 2 demonstrates the very significant proportion of out commuting to Greater Bristol for employment purposes from all the settlements across South Gloucestershire. The Plan, therefore, needs to recognise the impact of Bristol as a major employment hub on travel patterns and consequentially on Carbon emissions and Climate Change. SGC should therefore place greater weight on travel data to inform the location of new development to reduce journey trips and Carbon emissions rather than simply seeking to balance housing and employment at individual settlements.

27. Settlements around the Bristol Fringe, like Winterbourne which have been overlooked for development purposes due to Green Belt, would support a material and positive effect on Climate Change by encouraging low Carbon travel and shorter trips, particularly for employment purposes.

28. It is also noted that the Potential Urban Lifestyle locations are existing urban areas and whilst sites like Filton Airfield may yield greater development potential through higher densities, places like Yate, Thornbury and the East Fringe locations have grown through greenfield urban extensions. The ability for these places to intensify is therefore likely to have been largely exhausted therefore should not be overestimated at the expense of delivering much needed homes in the right locations to address Climate Change. It should also be noted that the Urban Lifestyle approach will compete with retaining employment land and the pressure to release it for housing. This is something that the emerging Plan should consider and balance appropriately.

29. Regarding Buildings Blocks 2, 3 and 4, a one size fits all approach is not going to deliver sustainable development or indeed, address Climate Change. Whilst the North East Fringe (Building Block 2) is a logical location to support reduced commuting into Bristol, there has been continual and rapid expansion over recent years. There are equally sustainable locations for planned new growth such as the nearby villages like Winterbourne.

30. In our view, Building Block 3 has limitations regarding sustainable development. Whilst settlements like Thornbury, Chipping Sodbury and Yate all have a range of local services and facilities and could support indigenous growth, a Plan which addresses the Council’s declared Climate Change Emergency will need to provide homes closest to where jobs are and recognise the influence that Bristol has in this regard. For example, Appendix 2 shows that due to the spread of employment destinations across Greater Bristol, a reliance on rail connections to improve the sustainability of commuting will only account for a very small proportion of travel from these settlements (currently 2%). Even with a doubling or tripling of this, it still represents a fraction of journeys travelled. As such, the approach to spatial planning should focus on shorter journey-to-work distances and encourage more flexible, Carbon efficient travel modes. This type of strategy will rely upon using the strong network of dedicated cycle routes to avoid wherever possible, the Carbon impact of major new engineering infrastructure. It will also rely on good quality bus routes and connections to the existing MetroBus network.

31. Waddeton Park supports the principles of Building Block 4. However, SGC is urged to re-look at this during the early stages of Plan preparation and specifically the impacts of reducing community distances/changing travel modes on the Climate Change Emergency. Moreover, a substantial response to the Climate Change Emergency represents an exceptional circumstance to review Green Belt boundaries at those sustainable settlements like Winterbourne and the encouragement of at least medium-scale growth as part of this Plan’s site allocation process.

32. Building Block 5 (free standing new settlement) is a more complex proposition in terms of addressing Climate Change and sustainability insofar as it relies upon building sustainability from scratch and the Carbon impact of additional infrastructure. For example, in the now abandoned JSP, land at Buckover was identified as a potential new settlement and whilst the Hearings did not take place, there was widespread concern about deliverability, sustainability and viability for this draft allocation. Conversely larger villages on the edge of Bristol can deliver the same quality and sustainability levels whilst being much closer to the employment base and facilities of the City. That proximity enables cycling and e-cycling to be utilised to access major employment areas on dedicated cycle routes into and around Greater Bristol. The proximity of Winterbourne to Greater Bristol will demonstrably reduce commuting distances and thus greatly support the response to Climate Change. Similarly, utilising Building Block 4 also enables existing services and facilities at settlements to be used in the short-term to underpin the sustainability of growth and in return growth will provide further enhancements to services and facilities.

33. In summary, given the spatial structure of South Gloucestershire, the position of the market towns to the North and the influence on employment commuting patterns of Greater Bristol to the South, more emphasis should be placed on exploring Building Block 4 to deliver a greater proportion of future growth.
17 May 2021 18:40
Ivywell Capital (IC) • Given the importance of the Bristol Urban Fringe and Yate as key service and employment centres, the most sustainable spatial distribution option will be one which directs the majority of development to these areas. This includes development at the rural villages well related to these areas and along key transit routes.

• This, coupled with the acuteness of the housing requirement, will likely necessitate the release of land from the Green Belt given that this wraps around the urban fringes of Bristol and Southern and Western edges of Yate. Exceptional circumstances are expected to be demonstrated on the basis that this will be required to achieve a sufficiently sustainable pattern of development.

• Whilst we would expect a significant proportion of development to be accommodated on large strategic sites, there are inherent risks and drawbacks with this approach that need to be addressed. Significant infrastructure costs, long-lead in times and viability issues can lead to significant delays in sites coming forward, or potential benefits reduced (e.g. lower affordable housing contributions/provisions).

• On large strategic sites the supply of new dwellings is also controlled to maximise selling prices which slows delivery of new homes including affordable homes.

• The reduced Plan period (15 years) compared with the JSP (20 years) also means that realistic assumptions about the delivery trajectories need to be identified to ensure sufficient housing will be delivered over the Plan period.

• It is imperative that the Council has confidence that any SDLs that are identified can be delivered and make a meaningful contribution to housing delivery, especially given the compressed Plan period. A failure to deliver housing in a timely manner will lead to a deficient housing land supply position, constrict economic growth and exacerbate affordability issues (inter alia).

• These risks can be mitigated to some degree through the identification of non-strategic levels of growth which can come forward promptly to underpin delivery in the early years of the Plan period whilst also delivering policy compliant levels of affordable housing.

• A balance will need to be struck in terms of the distribution between the two sources in order to ensure sufficiently sustainable patterns of development are achieved without jeopardising housing delivery; however, there is a clear imperative to direct growth toward the rural villages in the Green Belt and this is supported by the interim Sustainability Appraisal.

4.1 The building blocks identified broadly form the principal locations that one would expect to see a Local Plan utilise to deliver the development needs of the District. Typically, it will be a combination of most, if not all of these, that would help to secure the development needs of a District and achieve an appropriate balance between sustainability and deliverability.

4.2 Urban Areas, which are generally home to a good level of existing services, facilities, employment opportunities and Public Transport connections, are considered to be among the most sustainable locations for development. As such, we are supportive of development within these areas which will, generally, be the most sustainable locations for new development.

4.3 The difficulty is in anticipating a realistic quantum of development that will come forward from this source. We will comment further on any anticipated delivery from this source once this is more clearly defined in future consultations.

4.4 Regardless, it is rightly acknowledged within the Phase 1 document and Sustainability Appraisal (SA) that this source will not be able to meet the development needs of the District on its own and other 'building blocks' will need to be utilised within the spatial distribution strategy.

4.5 Urban Extensions are supported on the basis that the communities of the North and East Fringes already benefit from strong levels of employment, services, facilities and Public Transport connectivity and, therefore, there is good potential for development in these locations to achieve high standards of sustainability.

4.6 The Bristol North Fringe in particular boasts a wide range of services, facilities and employment opportunities with excellent Public Transport connections between them. Its importance as an employment hub for South Gloucestershire is also highlighted on page 47 of the infographic with significant levels of in commuting to the area, relative to out commuting (which is generally toward Central Bristol).

4.7 Given its importance and the limited scope for further growth within the confines of the M4/M5 boundary, careful consideration needs to be given in respect of how development can be sustainably delivered in order to take advantage of the service and employment provision within it. An appropriate level of growth at the villages around the Northern Fringe (e.g. Tockington and Olveston) would be well related to the Bristol Urban Fringe and could complement any strategic levels of growth which come forward elsewhere (e.g. along the A38 Corridor).

4.8 For similar reasons, Market Towns are also generally considered to be sustainable locations for development, albeit their level of service and employment provision is below that of the Bristol Urban Fringes. The three Market Towns identified are Yate, Thornbury and Chipping Sodbury. Whilst we would generally support development at these locations, one needs to be mindful of both their capacity to expand further and the wider factors that influence sustainability at a macro level.

4.9 The Rural Villages building block includes a number of settlements of varying size, significance and unique circumstances that will influence what level of development could come forward at them.

4.10 It is imperative that an appropriate level of development can come forward at the rural villages in the interests of maintaining their vitality and viability. This is important to address affordability issues within rural areas, breathe new life into communities and support existing services and facilities.

4.11 Villages such as Tockington and Olveston have a reasonable level of service provision within them, but have not been able to expand significantly in recent years as a result of the Green Belt constraints. This has exacerbated affordability issues within the village and put local services in danger of being lost (see above). Allocating a proportionate level of growth at villages such as these can help to support and enhance their vitality and viability and should be explored within the new Local Plan.

4.12 New Settlements can also make a valuable contribution to housing supply where there has been a sound approach to securing their delivery in a timely manner. Excellent examples of this would include the delivery of Cranbrook in East Devon and Northstowe in South Cambridge.

4.13 As acknowledged within the Consultation Document, careful consideration needs to be given to any identified opportunities. A significant level of reassurance will need to be provided that the needs of the new community will be met and that they will come forward in a reasonable timeframe.

4.14 New physical infrastructure (generally transport related) is often required to facilitate their delivery. The cost of this can either be prohibitive, affect viability or require external funding sources to secure their delivery. The latter is often reliant on being obtained via specific bid cycles. This can, in turn, affect the timely delivery of such new settlements. This will need to be borne in mind, especially given the shorter Plan period compared with the JSP.

4.15 It is also worth noting that viability considerations on strategic sites can adversely affect the delivery of other important benefits such as affordable housing. The East of Harry Stoke New Neighbourhood, for example, only considered capable of delivering around 25% affordable housing across the entire allocation without grant funding. This is significantly below the Core Strategy's overall affordable housing target of 35%. Non-strategic sites generally have the benefit of being able to deliver policy compliant levels of affordable housing (as a minimum).

4.16 The quantum of affordable housing that can be secured on site should be a consideration for the Council when weighing up the merits of different locations for growth and in determining the split between strategic and non-strategic levels of growth.

4.17 Once a set of sufficiently sustainable locations have been identified, deliverability should then be the key consideration in deciding which of these should be pursued. There are significant consequences associated with the failure of strategic sites to come forward (exacerbation of affordability issues, stymied economic growth, delays to key physical and social infrastructure etc). This is something that the Council should actively look to avoid.
17 May 2021 15:38
Bristol and England Properties… 4.2 Urban Areas, which are generally home to a good level of existing services, facilities, employment opportunities and Public Transport connections, are considered to be among the most sustainable locations for development. As such, we are supportive of development within these areas which will, generally, be the most sustainable locations for new development.

4.3 The difficulty is in anticipating a realistic quantum of development that will come forward from this source. We will comment further on any anticipated delivery from this source once this is more clearly defined in future consultations.

4.4 Regardless, it is rightly acknowledged within the Phase 1 document and Sustainability Appraisal (SA) that this source will not be able to meet the development needs of the District on its own and other 'building blocks' will need to be utilised within the spatial distribution strategy.

4.5 Urban Extensions are supported on the basis that the communities of the North and East Fringes already benefit from strong levels of employment, services, facilities and Public Transport connectivity and, therefore, there is good potential for development in these locations to achieve high standards of sustainability.

4.6 The Bristol North Fringe in particular boasts a wide range of services, facilities and employment opportunities with excellent Public Transport connections between them. Its importance as an employment hub for South Gloucestershire is also highlighted on page 47 of the infographic with significant levels of in commuting to the area, relative to out commuting (which is generally toward Central Bristol).

4.7 Given its importance and the limited scope for further growth within the confines of the M4/M5 boundary, careful consideration needs to be given in respect of how development can be sustainably delivered in order to take advantage of the service and employment provision within it. An appropriate level of growth at the villages around the Northern Fringe (e.g. Tockington and Olveston) would be well related to the Bristol Urban Fringe and could complement any strategic levels of growth which come forward elsewhere (e.g. along the A38 Corridor).

4.8 For similar reasons, Market Towns are also generally considered to be sustainable locations for development, albeit their level of service and employment provision is below that of the Bristol Urban Fringes. The three Market Towns identified are Yate, Thornbury and Chipping Sodbury. Whilst we would generally support development at these locations, one needs to be mindful of both their capacity to expand further and the wider factors that influence sustainability at a macro level.

4.9 For example, Thornbury has had significant levels of growth committed already at the town (c. 650 dwellings) which is expected to come forward over much of the Plan period. One may question whether there is enough latent demand to support further significant levels of growth under this Plan period, or if there needs to be a period of consolidation as existing commitments are built out.

4.10 Turning to Chipping Sodbury, whilst it has not been subject to significant levels of growth in recent years, one would need to examine the benefits of directing development to this location against alternative options. Whilst it would have good access to Yate and reasonable Public Transport connections to the fringes of Bristol, one questions whether development here is truly best located to maximise opportunities for active/public modes of transport. For example, development at Frampton Cotterell/Coalpit Heath or the North West of Yate would be much better related to these key areas of the District and better placed to maximise active and Public Transport opportunities (e.g. MetroBus extension, the strategic rail network and key employment centres).

4.11 As such, we generally only see Yate as a primary candidate in terms of being capable of delivering further large-scale growth within the most optimal sustainable strategy.

4.12 The Rural Villages building block includes a number of settlements of varying size, significance and unique circumstances that will influence what level of development could come forward at them.

4.13 For example, Frampton Cotterell, Coalpit Heath and Winterbourne are larger villages in and of themselves which all scored well in sustainability terms within the Rural Settlements Topic Paper[3]. In reality, the three settlements effectively function as a single entity with a range of services, facilities and employment opportunities across all three which complement each other to support the majority of the needs of their residents. These settlements could, therefore, be capable of accommodating significant levels of growth.

4.14 Frampton Cotterell and Coalpit Heath specifically are set to benefit from a MetroBus route along the A432 Corridor which will provide a frequent and convenient connection between Yate and the Bristol Urban Fringe further enhancing its sustainability credentials.

4.15 There is a clear distinction between settlements like this and those within tiers of the aforementioned Topic Paper which, whilst they benefit from some service provision, are simply not at the same 'level' as Frampton Cotterell in terms of access to services, facilities, Schools, employment opportunities or Public Transport connections.

4.16 There is an excellent opportunity to deliver significant scales of growth at Frampton Cotterell, Coalpit Heath and Winterbourne and this was reflected in the fact that land was identified for strategic development in the JSP to the East of the 'conurbation.' However, there are other opportunities within the settlement that could be explored to complement large scale strategic growth. This includes our client's site in Frampton Cotterell.

4.17 Beyond Frampton Cotterell, Coalpit Heath and Winterbourne, the majority of other rural villages do not benefit from as significant a provision of services, facilities, employment opportunities or Public Transport connections and so a more modest level of growth should be directed toward them. However, it is imperative that an appropriate level of development can come forward at the rural villages in the interests of maintaining their vitality and viability. This is important to address affordability issues within rural areas, breathe new life into communities and support existing services and facilities.

[3] South Gloucestershire Local Plan Rural Settlements and Villages 2015 Topic Paper (November 2015).

4.18 Villages such as Tockington and Olveston have a reasonable level of service provision within them, but have not been able to expand significantly in recent years as a result of the Green Belt constraints. This has exacerbated affordability issues within the village and put local services in danger of being lost (see above). Allocating a proportionate level of growth at villages such as these can help to support and enhance their vitality and viability and should be explored within the new Local Plan.

4.19 New Settlements can also make a valuable contribution to housing supply where there has been a sound approach to securing their delivery in a timely manner. Excellent examples of this would include the delivery of Cranbrook in East Devon and Northstowe in South Cambridge.

4.20 As acknowledged within the Consultation Document, careful consideration needs to be given to any identified opportunities. A significant level of reassurance will need to be provided that the needs of the new community will be met and that they will come forward in a reasonable timeframe.

4.21 New physical infrastructure (generally transport related) is often required to facilitate their delivery. The cost of this can either be prohibitive, affect viability or require external funding sources to secure their delivery. The latter is often reliant on being obtained via specific bid cycles. This can, in turn, affect the timely delivery of such new settlements. This will need to be borne in mind, especially given the shorter Plan period compared with the JSP.

4.22 It is also worth noting that viability considerations on strategic sites can adversely affect the delivery of other important benefits such as affordable housing. The East of Harry Stoke New Neighbourhood, for example, only considered capable of delivering around 25% affordable housing across the entire allocation without grant funding. This is significantly below the Core Strategy's overall affordable housing target of 35%. Non-strategic sites generally have the benefit of being able to deliver policy compliant levels of affordable housing (as a minimum).

4.23 The quantum of affordable housing that can be secured on site should be a consideration for the Council when weighing up the merits of different locations for growth and in determining the split between strategic and non-strategic levels of growth.

4.24 Once a set of sufficiently sustainable locations have been identified, deliverability should then be the key consideration in deciding which of these should be pursued. There are significant consequences associated with the failure of strategic sites to come forward (exacerbation of affordability issues, stymied economic growth, delays to key physical and social infrastructure etc). This is something that the Council should actively look to avoid.
17 May 2021 10:52
South West Housing Association… Of the remaining four building blocks set out in the consultation document, the HAPC acknowledges the potential of all four options to deliver housing in sustainable locations. It is essential that housing is in sustainable locations close to existing or new facilities, services and jobs and in locations that are or will be well connected and accessible. It is essential that affordable housing is developed in sustainable locations to enable residents to thrive in an established support network.

There is a pressing need for South Gloucestershire to build more homes, so it is imperative that South Gloucestershire takes a proactive Plan led approach and allocates sufficient sites in the new Local Plan. Understanding the consultation document, it appears that progressing any of the four building block numbers 2 to 5 would likely result in a review of the Green Belt in order to identify the best locations for development. The NPPF permits alterations to Green Belt boundaries through the production of a new Local Plan where exceptional circumstances are fully evidenced and justified.

We encourage the Council to consider reviewing the role of each of its settlements and their corresponding settlement boundaries. The supporting text for building block 4 acknowledges that there are a number of smaller settlements that are ‘washed over’ by the Green Belt. Page 114 of the consultation document describes how development in the rural settlements of South Gloucestershire has mostly been restricted to infill opportunities and that the benefits of well-planned growth has not been felt. In addition, the Council had also found that its rural settlements have been subject to speculative Applications. Reviewing the settlement boundaries will help to prevent such speculative development while providing opportunities for development to meet rural housing need. Well-planned housing growth can provide market and much needed affordable housing, new employment opportunities, improved infrastructure and it often supports existing local services and facilities.

Green Belt:

Referring to the two options for investigating the Green Belt as shown on page 132, we show support for Option 2 as it provides the broadest range of options for future development as it considers a larger number of villages and settlements to deliver the homes needed for communities across South Gloucestershire. It is likely that buildings blocks 2 to 5 of the proposed development strategy would require some form of Green Belt review in order to undergo assessment and suitability.

The NPPF permits alterations to Green Belt boundaries through the production of a new Local Plan where exceptional circumstances are fully evidenced and justified. Key strategic policies, such as market and affordable housing need, should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term so they can endure beyond the Plan period. For this reason we would advise that there may well be a case for releasing sites from the Green Belt, given the growing pressure for additional housing within the Authority area and the need for it to be in sustainable locations.
14 May 2021 19:19
Newland Homes - Land at Aust Road 4.2 Urban Areas, which are generally home to a good level of existing services, facilities, employment opportunities and Public Transport connections, are considered to be among the most sustainable locations for development. As such, we are supportive of development within these areas which will, generally, be the most sustainable locations for new development.

4.3 The difficulty is in anticipating a realistic quantum of development that will come forward from this source. We will comment further on any anticipated delivery from this source once this is more clearly defined in future consultations.

4.4 Regardless, it is rightly acknowledged within the Phase 1 document and Sustainability Appraisal (SA) that this source will not be able to meet the development needs of the District on its own and other 'building blocks' will need to be utilised within the spatial distribution strategy.

4.5 Urban Extensions are supported on the basis that the communities of the North and East Fringes already benefit from strong levels of employment, services, facilities and Public Transport connectivity and, therefore, there is good potential for development in these locations to achieve high standards of sustainability.

4.6 The Bristol North Fringe in particular boasts a wide range of services, facilities and employment opportunities with excellent Public Transport connections between them. Its importance as an employment hub for South Gloucestershire is also highlighted on page 47 of the infographic with significant levels of in commuting to the area, relative to out commuting (which is generally toward Central Bristol).

4.7 Given its importance and the limited scope for further growth within the confines of the M4/M5 boundary, careful consideration needs to be given in respect of how development can be sustainably delivered in order to take advantage of the service and employment provision within it. An appropriate level of growth at the villages around the Northern Fringe (e.g. Olveston and Tockington) would be well related to the Bristol Urban Fringe and could complement any strategic levels of growth which come forward elsewhere (e.g. along the A38 corridor).

4.8 For similar reasons, Market Towns are also generally considered to be sustainable locations for development, albeit their level of service and employment provision is below that of the Bristol Urban Fringes. The three Market Towns identified are Yate, Thornbury and Chipping Sodbury. Whilst we would generally support development at these locations, one needs to be mindful of both their capacity to expand further and the wider factors that influence sustainability at a macro level.

4.9 For example, Thornbury has had significant levels of growth committed already at the town (c. 650 dwellings) which is expected to come forward over much of the Plan period. One may question whether there is enough latent demand to support further significant levels of growth under this Plan period, or if there needs to be a period of consolidation as existing commitments are built out. There is opportunity for some smaller sites closer to the Thornbury Town centre to come forward rather than continuing to add to the periphery of the town where facilities are sparse and relies on car use.

4.10 Turning to Chipping Sodbury, whilst it has not been subject to significant levels of growth in recent years, one would need to examine the benefits of directing development to this location against alternative options. Whilst it would have good access to Yate and reasonable Public Transport connections to the fringes of Bristol, one questions whether development here is truly best located to maximise opportunities for active/public modes of transport. For example, development at to the North of Yate would be much better related to these key areas of the District and better placed to maximise active and Public Transport opportunities (e.g. MetroBus extension, the strategic rail network and key employment centres).

4.11 Large-scale growth should be delivered in line with an optimally sustainable strategy.

4.12 The Rural Villages building block includes a number of settlements of varying size, significance and unique circumstances that will influence what level of development could come forward at them.

4.13 Aside from a handful of the rural villages (e.g. Coalpit Heath, Frampton Cotterell, Winterbourne and Charfield), the majority of other rural villages do not benefit from as significant a provision of services, facilities, employment opportunities or Public Transport connections and so a more modest level of growth should be directed toward them. However, it is imperative that an appropriate level of development can come forward at the rural villages in the interests of maintaining their vitality and viability. This is important to address affordability issues within rural areas, breathe new life into communities and support existing services and facilities.

4.14 Villages such as Tockington and Olveston have a reasonable level of service provision within them, but have not been able to expand significantly in recent years as a result of Green Belt constraints. This has exacerbated affordability issue within the villages and put local services in danger of being lost. Allocating a proportionate level of growth at villages such as these can help to support and enhance their vitality and viability and should be explored within the new Local Plan.

4.15 New Settlements can also make a valuable contribution to housing supply where there has been a sound approach to securing their delivery in a timely manner. Excellent examples of this would include the delivery of Cranbrook in East Devon and Northstowe in South Cambridge.

4.16 As acknowledged within the Consultation Document, careful consideration needs to be given to any identified opportunities. A significant level of reassurance will need to be provided that the needs of the new community will be met and that they will come forward in a reasonable timeframe.

4.17 New physical infrastructure (generally transport related) is often required to facilitate their delivery. The cost of this can either be prohibitive, affect viability or require external funding sources to secure their delivery. The latter is often reliant on being obtained via specific bid cycles. This can, in turn, affect the timely delivery of such new settlements. This will need to be borne in mind, especially given the shorter Plan period compared with the JSP.

4.18 Once a set of sufficiently sustainable locations have been identified, deliverability should then be the key consideration in deciding which of these should be pursued. There are significant consequences associated with the failure of strategic sites to come forward (exacerbation of affordability issues, stymied economic growth, delays to key physical and social infrastructure etc). This is something that the Council should actively look to avoid.
14 May 2021 17:12
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