South Gloucestershire New Local Plan Phase 1 Responses

Local Plan 2020

List of answers to the specified question
NameResponseDate
Redcliffe Homes Please see enclosed representations. 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. 01 Jun 2021 12:24
Hannah Saunders - Dodington Pa… Page 66 – INVESTIGATING THE GREEN BELT:

• While Members feel that any loss of Green Belt should be the last resort they feel that some sympathetic development could be advantageous under strict conditions (Also see comments on pages 113 - 136).

Page 72 – Green infrastructure and nature recovery networks:

• Members strongly support a holistic approach to these aspects.

Page 72 – Balance between local jobs and resident workers:

• Members strongly support reducing need to travel for work and strongly support providing more, and more varied, local employment opportunities.
25 May 2021 16:13
Waddeton Park Ltd - Land at Hi… 42. There is varied reference to building and sustaining communities, but we believe this should be a Guiding Principle in its own right. It may include matters such as describing what a walkable neighbourhood is and what land uses it may consist of? It should focus on social and health matters which any good development will address.

43. Alternative modes of travel such as, E-bicycle and e-scooter should form part of Guiding Principle 1 given that they bridge the gap between the walkable neighbourhood and necessary wider travel. Our Client is keen to see a Plan which supports Bristol as the ‘Cycling City’ and offering the extension of this mode of travel into South Gloucestershire by enabling slightly longer distance journeys to become more convenient. When journey to work data is examined, settlements immediately around the Greater Bristol area are most likely to benefit from this. Likewise, it provides much more flexibility than bus which rely on set times and routes that do not always correspond with where and when people need to travel for work. The benefits of this approach are set out in the technical note in Appendix 2.
17 May 2021 18:40
Ivywell Capital (IC) 1. Locate new homes, jobs or settlements in places where key services and facilities are easily accessed by walking and cycling or effective Public Transport, or alternatively in locations where key services and facilities are capable of being provided as part of the new development.

4.19 Agree. There are numerous benefits associated with locating development in places with either good existing access to services and facilities or the potential to make them accessible.

4.20 This goes beyond the general imperative to reduce reliance on the private motor vehicle to combat Carbon emissions and Climate Change which is the obvious key benefit. Greater accessibility to said services and facilities helps combat other social and economic issues such as loneliness and unemployment, especially where the use of a private motor vehicle is not an option (e.g. for younger, older and disabled residents).

4.21 Increased use of active modes of transport also supports healthier lifestyles and the closer people live to key services and facilities, the more attractive these options become. This is also true of Public Transport where more frequent and shorter journey times go hand in hand with increased usage. Again, this is likely to be achieved where development is located in close proximity to services, facilities and existing transport routes.

4.22 The other advantage is that, where the private motor vehicle is used, journeys will typically be shorter and, therefore, emissions will be lower as a result.

4.23 The application of this principle will generally (although not necessarily always) lead to the identification of the more sustainable locations of development and, as such, we support this as a guiding principle.

2. Sequential approach to building on areas at a high risk of flooding.

4.24 Agree. Paragraph 157 of the NPPF states that, "all Plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of Climate Change so as to avoid, where possible, flood risk to people and property. They should do this, and manage any residual risk, by:

a) Applying the sequential test and then, if necessary, the exception test as set out below;

b) Safeguarding land from development that is required, or likely to be required, for current or future flood management;

c) Using opportunities provided by new development to reduce the causes and impacts of flooding (where appropriate through the use of natural flood management techniques); and

d) Where Climate Change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to relocate development, including housing, to more sustainable locations."

4.25 Paragraph 158 of the NPPF follows this up by stating that "Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding.… The sequential approach should be used in areas known to be at risk now or in the future from any form of flooding."

4.26 National Policy is clear in the importance of steering new development away from areas at risk of flooding. Indeed, paragraph 158 is clear in its directive that development should not be allocated or permitted where there are reasonably available sites in areas with a lower risk of flooding.

4.27 This is not to say that development within areas at risk of flooding is always unacceptable and indeed there may be good reasons for doing so, say, where there are clear sustainability benefits or a lack of land in areas at lower risks of flooding. However, as a general principle, sites in Flood Zone 1 should take precedence over sites in Flood Zones 2 and 3 when it comes to identifying sites for development.

4.28 When applying the sequential approach through the Local Plan process, we would stress that a site's Green Belt designation should not be something which dictates whether it is reasonably available or not. This is because the Local Plan process allows for revisions to Green Belt boundaries where there are exceptional circumstances for doing so.

4.29 This is different to the very special circumstances that need to be demonstrated under the development management process in order to allow development in the Green Belt and that would otherwise allow a site to be discounted within any sequential assessment.

4.30 Indeed, the need to avoid areas of flood risk can be a contributing factor to demonstrating the exceptional circumstances for releasing land from the Green Belt as there are sound environmental and social reasons for doing so. The judgment in the 2015 court case Calverton Parish Council v Greater Nottingham Council & Others (EWHC 1078) identifies five matters to consider when assessing whether exceptional circumstances are present. One such identified circumstance was the "consequent difficulties in securing sustainable development without impinging on the Green Belt."

4.31 The development of greenfield sites in areas of flood risk is inherently unsustainable given that it exacerbates the potential impacts of Climate Change and increases the risks to human life and property. Assuming that the development needs of the District could not be met on sustainable locations outside the Green Belt on land entirely within Flood Zone 1, then this would constitute an exceptional circumstance that would justify development in the Green Belt.

4.32 In short, National Policy is clear in that development should be steered away from areas of high flood risk. Key reasons for this are to mitigate the potential impacts of Climate Change and minimise the risk to human life and property. The need to avoid areas of flood risk would be a contributing factor to justifying the release of Green Belt sites in sustainable locations.

3. Protect and enhance ecological, landscape and heritage designations and their settings.

4.33 Agree. The level of protection afforded should be proportionate to their relative significance, as dictated by the NPPF and relevant legislation. For all potential strategic allocations, the public benefits may need to be weighed against any harms through the Sustainability Appraisal process.

4. Protect and enhance the function and connectivity of our Green Infrastructure and Nature Recovery Networks.

4.34 Agree. As above, the level of protection afforded should be proportionate and appropriate to the significance of said asset. Proposals should also be considered on a wholistic basis, with the net gains that could be facilitated through the loss of certain features that may be necessary to enable development to come forward.

5. Plan for a better balance between local jobs and resident workers in our communities.

4.35 Agree. The need to commute to and from work is unavoidable for many and this is often done by the private motor vehicle. Locating development in close proximity to areas with good access to existing employment centres and/or delivering employment alongside new residential development can help to promote the use of walking, cycling and Public Transport as an alternative to the private motor vehicle.

4.36 There are also social benefits in achieving a good balance between local jobs and resident workers. Offering alternative (and cheaper) options to the private motor vehicle will improve accessibility to employment for many people, some of whom may not own a car.

4.37 Inherently, development at certain rural villages would appear to run against this principle. However, this does not mean that development should not be directed towards villages where reliance on the private motor vehicle is likely to remain relatively high for the reasons set out above.

4.38 Furthermore, there has been a significant shift in working and travel patterns as a result of the pandemic with many working from home on a permanent or semi-permanent basis. As such, the sustainability drawbacks to development at rural settlements have been slightly diminished, especially where digital connectivity is good.

6. Ensuring that we protect a ‘sense of place and character’ when we plan for new development.

4.39 We support this principle in the sense that the protection of place and character should be sought where the current sense of place and character is worth preserving. Opportunities to enhance, improve and create a new sense of place and character should also be explored where the context dictates.

4.40 Whilst we agree with the guiding principles as a sound way in which to identify sustainable locations for growth, the absence of 'deliverability' as a principle is of some concern. As has been alluded to in the Phase 1 document, deliverability issues have led to the Council being unable to demonstrate a robust housing land supply in recent years. This has led to speculative development at many of the non-Green Belt towns and villages coming forward in recent years. Again, whilst this development is not fundamentally unsustainable in nature, it sits outside of an agreed framework which would most likely deliver more sustainable development in the round.

4.41 Deliverability, or rather a failure to deliver the housing to meet the District's needs, also has significant social and economic consequences which we have touched on above and are considered in the latest SA.

4.42 We accept that deliverability considerations may not be appropriate for the purposes of identifying potential locations for development. However, it should certainly form part of any site sifting exercise that may be undertaken, once these options have been identified.

4.43 We would suggest a deliverability metric be applied to all options considered and those considered to be at significant risk of delivery, should be screened out at an appropriate stage.
17 May 2021 15:38
Bristol and England Properties… 1. Locate new homes, jobs or settlements in places where key services and facilities are easily accessed by walking and cycling or effective Public Transport, or alternatively in locations where key services and facilities are capable of being provided as part of the new development.

4.26 Agree. There are numerous benefits associated with locating development in places with either good existing access to services and facilities or the potential to make them accessible.

4.27 This goes beyond the general imperative to reduce reliance on the private motor vehicle to combat Carbon emissions and Climate Change which is the obvious key benefit. Greater accessibility to said services and facilities helps combat other social and economic issues such as loneliness and unemployment, especially where the use of a private motor vehicle is not an option (e.g. for younger, older and disabled residents).

4.28 Increased use of active modes of transport also supports healthier lifestyles and the closer people live to key services and facilities, the more attractive these options become. This is also true of Public Transport where more frequent and shorter journey times go hand in hand with increased usage. Again, this is likely to be achieved where development is located in close proximity to services, facilities and existing transport routes.

4.29 The other advantage is that, where the private motor vehicle is used, journeys will typically be shorter and, therefore, emissions will be lower as a result.

4.30 The application of this principle will generally (although not necessarily always) lead to the identification of the more sustainable locations of development and, as such, we support this as a guiding principle.

2. Sequential approach to building on areas at a high risk of flooding.

4.31 Agree. Paragraph 157 of the NPPF states that, "all Plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of Climate Change so as to avoid, where possible, flood risk to people and property. They should do this, and manage any residual risk, by:

a) Applying the sequential test and then, if necessary, the exception test as set out below;

b) Safeguarding land from development that is required, or likely to be required, for current or future flood management;

c) Using opportunities provided by new development to reduce the causes and impacts of flooding (where appropriate through the use of natural flood management techniques); and

d) Where Climate Change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to relocate development, including housing, to more sustainable locations."

4.32 Paragraph 158 of the NPPF follows this up by stating that "Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding…. The sequential approach should be used in areas known to be at risk now or in the future from any form of flooding."

4.33 National Policy is clear in the importance of steering new development away from areas at risk of flooding. Indeed, paragraph 158 is clear in its directive that development should not be allocated or permitted where there are reasonably available sites in areas with a lower risk of flooding.

4.34 This is not to say that development within areas at risk of flooding is always unacceptable and indeed there may be good reasons for doing so, say, where there are clear sustainability benefits or a lack of land in areas at lower risks of flooding. However, as a general principle, sites in Flood Zone 1 should take precedence over sites in Flood Zones 2 and 3 when it comes to identifying sites for development.

4.35 When applying the sequential approach through the Local Plan process, we would stress that a site's Green Belt designation should not be something which dictates whether it is reasonably available or not. This is because the Local Plan process allows for revisions to Green Belt boundaries where there are exceptional circumstances for doing so.

4.36 This is different to the very special circumstances that need to be demonstrated under the development management process in order to allow development in the Green Belt and that would otherwise allow a site to be discounted within any sequential assessment.

4.37 Indeed, the need to avoid areas of flood risk can be a contributing factor to demonstrating the exceptional circumstances for releasing land from the Green Belt as there are sound environmental and social reasons for doing so. The judgment in the 2015 court case Calverton Parish Council v Greater Nottingham Council & Others (EWHC 1078) identifies five matters to consider when assessing whether exceptional circumstances are present. One such identified circumstance was the "consequent difficulties in securing sustainable development without impinging on the Green Belt."

4.38 The development of greenfield sites in areas of flood risk is inherently unsustainable given that it exacerbates the potential impacts of Climate Change and increases the risks to human life and property. Assuming that the development needs of the District could not be met on sustainable locations outside the Green Belt on land entirely within Flood Zone 1, then this would constitute an exceptional circumstance that would justify development in the Green Belt.

4.39 In short, National Policy is clear in that development should be steered away from areas of high flood risk. Key reasons for this are to mitigate the potential impacts of Climate Change and minimise the risk to human life and property. The need to avoid areas of flood risk would be a contributing factor to justifying the release of Green Belt sites in sustainable locations.

3. Protect and enhance ecological, landscape and heritage designations and their settings.

4.40 Agree. The level of protection afforded should be proportionate to their relative significance, as dictated by the NPPF and relevant legislation. For all potential strategic allocations, the public benefits may need to be weighed against any harms through the Sustainability Appraisal process.

4. Protect and enhance the function and connectivity of our Green Infrastructure and Nature Recovery Networks.

4.41 Agree. As above, the level of protection afforded should be proportionate and appropriate to the significance of said asset. Proposals should also be considered on a wholistic basis, with the net gains that could be facilitated through the loss of certain features that may be necessary to enable development to come forward.

5. Plan for a better balance between local jobs and resident workers in our communities.

4.42 Agree. The need to commute to and from work is unavoidable for many and this is often done by the private motor vehicle. Locating development in close proximity to areas with good access to existing employment centres and/or delivering employment alongside new residential development can help to promote the use of walking, cycling and Public Transport as an alternative to the private motor vehicle.

4.43 There are also social benefits in achieving a good balance between local jobs and resident workers. Offering alternative (and cheaper) options to the private motor vehicle will improve accessibility to employment for many people, some of whom may not own a car.

4.44 Inherently, development at certain rural villages would appear to run against this principle. However, this does not mean that development should not be directed towards villages where reliance on the private motor vehicle is likely to remain relatively high for the reasons set out above.

4.45 Furthermore, there has been a significant shift in working and travel patterns as a result of the pandemic with many working from home on a permanent or semi-permanent basis. As such, the sustainability drawbacks to development at rural settlements have been slightly diminished, especially where digital connectivity is good.

6. Ensuring that we protect a ‘sense of place and character’ when we plan for new development.

4.46 We support this principle in the sense that the protection of place and character should be sought where the current sense of place and character is worth preserving. Opportunities to enhance, improve and create a new sense of place and character should also be explored where the context dictates.

Do you think we have missed any key, initial guiding principles?

4.47 Whilst we agree with the guiding principles as a sound way in which to identify sustainable locations for growth, the absence of 'deliverability' as a principle is of some concern. As has been alluded to in the Phase 1 document, deliverability issues have led to the Council being unable to demonstrate a robust housing land supply in recent years. This has led to speculative development at many of the non-Green Belt towns and villages coming forward in recent years. Again, whilst this development is not fundamentally unsustainable in nature, it sits outside of an agreed framework which would most likely deliver more sustainable development in the round.

4.48 Deliverability, or rather a failure to deliver the housing to meet the District's needs, also has significant social and economic consequences which we have touched on above and are considered in the latest SA.

4.49 We accept that deliverability considerations may not be appropriate for the purposes of identifying potential locations for development. However, it should certainly form part of any site sifting exercise that may be undertaken, once these options have been identified.

4.50 We would suggest a deliverability metric be applied to all options considered and those considered to be at significant risk of delivery, should be screened out at an appropriate stage.
17 May 2021 10:52
Newland Homes - Land at Aust Road 4.19 Our comments on the six guiding principles are listed below:

1. Locate new homes, jobs or settlements in places where key services and facilities are easily accessed by walking and cycling or effective Public Transport, or alternatively in locations where key services and facilities are capable of being provided as part of the new development.

4.20 Agree. There are numerous benefits associated with locating development in places with either good existing access to services and facilities or the potential to make them accessible.

4.21 This goes beyond the general imperative to reduce reliance on the private motor vehicle to combat Carbon emissions and Climate Change which is the obvious key benefit. Greater accessibility to said services and facilities helps combat other social and economic issues such as loneliness and unemployment, especially where the use of a private motor vehicle is not an option (e.g. for younger, older and disabled residents).

4.22 Increased use of active modes of transport also supports healthier lifestyles and the closer people live to key services and facilities, the more attractive these options become. This is also true of Public Transport where more frequent and shorter journey times go hand in hand with increased usage. Again, this is likely to be achieved where development is located in close proximity to services, facilities and existing transport routes.

4.23 The other advantage is that, where the private motor vehicle is used, journeys will typically be shorter and, therefore, emissions will be lower as a result.

4.24 The application of this principle will generally (although not necessarily always) lead to the identification of the more sustainable locations of development and, as such, we support this as a guiding principle.

2. Sequential approach to building on areas at a high risk of flooding.

4.25 Agree. Paragraph 157 of the NPPF states that, "all Plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of Climate Change so as to avoid, where possible, flood risk to people and property. They should do this, and manage any residual risk, by:

a) Applying the sequential test and then, if necessary, the exception test as set out below;

b) Safeguarding land from development that is required, or likely to be required, for current or future flood management;

c) Using opportunities provided by new development to reduce the causes and impacts of flooding (where appropriate through the use of natural flood management techniques); and

d) Where Climate Change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to relocate development, including housing, to more sustainable locations."

4.26 Paragraph 158 of the NPPF follows this up by stating that "Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding.… The sequential approach should be used in areas known to be at risk now or in the future from any form of flooding."

4.27 National Policy is clear in the importance of steering new development away from areas at risk of flooding. Indeed, paragraph 158 is clear in its directive that development should not be allocated or permitted where there are reasonably available sites in areas with a lower risk of flooding.

4.28 This is not to say that development within areas at risk of flooding is always unacceptable and indeed there may be good reasons for doing so, say, where there are clear sustainability benefits or a lack of land in areas at lower risks of flooding. However, as a general principle, sites in Flood Zone 1 should take precedence over sites in Flood Zones 2 and 3 when it comes to identifying sites for development.

4.29 When applying the sequential approach through the Local Plan process, we would stress that a site's Green Belt designation should not be something which dictates whether it is reasonably available or not. This is because the Local Plan process allows for revisions to Green Belt boundaries where there are exceptional circumstances for doing so.

4.30 This is different to the very special circumstances that need to be demonstrated under the development management process in order to allow development in the Green Belt and that would otherwise allow a site to be discounted within any sequential assessment.

4.31 Indeed, the need to avoid areas of flood risk can be a contributing factor to demonstrating the exceptional circumstances for releasing land from the Green Belt as there are sound environmental and social reasons for doing so. The judgment in the 2015 court case Calverton Parish Council v Greater Nottingham Council & Others (EWHC 1078) identifies five matters to consider when assessing whether exceptional circumstances are present. One such identified circumstance was the "consequent difficulties in securing sustainable development without impinging on the Green Belt."

4.32 The development of greenfield sites in areas of flood risk is inherently unsustainable given that it exacerbates the potential impacts of Climate Change and increases the risks to human life and property. Assuming that the development needs of the District could not be met on sustainable locations outside the Green Belt on land entirely within Flood Zone 1, then this would constitute an exceptional circumstance that would justify development in the Green Belt.

4.33 In short, National Policy is clear in that development should be steered away from areas of high flood risk. Key reasons for this are to mitigate the potential impacts of Climate Change and minimise the risk to human life and property. The need to avoid areas of flood risk would be a contributing factor to justifying the release of Green Belt sites in sustainable locations.

3. Protect and enhance ecological, landscape and heritage designations and their settings.

4.34 Agree. The level of protection afforded should be proportionate to their relative significance, as dictated by the NPPF and relevant legislation. For all potential strategic allocations, the public benefits may need to be weighed against any harms through the Sustainability Appraisal process.

4. Protect and enhance the function and connectivity of our Green Infrastructure and Nature Recovery Networks.

4.35 Agree. As above, the level of protection afforded should be proportionate and appropriate to the significance of said asset. Proposals should also be considered on a wholistic basis, with the net gains that could be facilitated through the loss of certain features that may be necessary to enable development to come forward.

5. Plan for a better balance between local jobs and resident workers in our communities.

4.36 Agree. The need to commute to and from work is unavoidable for many and this is often done by the private motor vehicle. Locating development in close proximity to areas with good access to existing employment centres and/or delivering employment alongside new residential development can help to promote the use of walking, cycling and Public Transport as an alternative to the private motor vehicle.

4.37 There are also social benefits in achieving a good balance between local jobs and resident workers. Offering alternative (and cheaper) options to the private motor vehicle will improve accessibility to employment for many people, some of whom may not own a car.

4.38 Intuitively, development at certain rural villages would appear to run against this principle. However, this does not mean that development should not be directed towards villages where reliance on the private motor vehicle is likely to remain relatively high for the reasons set out above.

4.39 Furthermore, there has been a significant shift in working and travel patterns as a result of the pandemic with many working from home on a permanent or semi-permanent basis. As such, the sustainability drawbacks to development at rural settlements have been slightly diminished, especially where digital connectivity is good.

6. Ensuring that we protect a ‘sense of place and character’ when we plan for new development.

4.40 We support this principle in the sense that the protection of place and character should be sought where the current sense of place and character is worth preserving. Opportunities to enhance, improve and create a new sense of place and character should also be explored where the context dictates.

Do you think we have missed any key, initial guiding principles?

4.41 Whilst we agree with the guiding principles as a sound way in which to identify sustainable locations for growth, the absence of 'deliverability' as a principle is of some concern. As has been alluded to in the Phase 1 document, deliverability issues have led to the Council being unable to demonstrate a robust housing land supply in recent years. This has led to speculative development at many of the non-Green Belt towns and villages coming forward in recent years. Again, whilst this development is not fundamentally unsustainable in nature, it sits outside of an agreed framework which would most likely deliver more sustainable development in the round.

4.42 Deliverability, or rather a failure to deliver the housing to meet the District's needs, also has significant social and economic consequences which we have touched on above and are considered in the latest SA.

4.43 We accept that deliverability considerations may not be appropriate for the purposes of identifying potential locations for development. However, it should certainly form part of any site sifting exercise that may be undertaken, once these options have been identified.

4.44 We would suggest a deliverability metric be applied to all options considered and those considered to be at significant risk of delivery, should be screened out at an appropriate stage.
14 May 2021 17:12
Newland Homes - Land West of T… 4.18 Our comments on the six guiding principles are listed below:

1. Locate new homes, jobs or settlements in places where key services and facilities are easily accessed by walking and cycling or effective Public Transport, or alternatively in locations where key services and facilities are capable of being provided as part of the new development.

4.19 Agree. There are numerous benefits associated with locating development in places with either good existing access to services and facilities or the potential to make them accessible.

4.20 This goes beyond the general imperative to reduce reliance on the private motor vehicle to combat Carbon emissions and Climate Change which is the obvious key benefit. Greater accessibility to said services and facilities helps combat other social and economic issues such as loneliness and unemployment, especially where the use of a private motor vehicle is not an option (e.g. for younger, older and disabled residents).

4.21 Increased use of active modes of transport also supports healthier lifestyles and the closer people live to key services and facilities, the more attractive these options become. This is also true of Public Transport where more frequent and shorter journey times go hand in hand with increased usage. Again, this is likely to be achieved where development is located in close proximity to services, facilities and existing transport routes.

4.22 The other advantage is that, where the private motor vehicle is used, journeys will typically be shorter and, therefore, emissions will be lower as a result.

4.23 The application of this principle will generally (although not necessarily always) lead to the identification of the more sustainable locations of development and, as such, we support this as a guiding principle.

2. Sequential approach to building on areas at a high risk of flooding.

4.24 Agree. Paragraph 157 of the NPPF states that, "all Plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of Climate Change so as to avoid, where possible, flood risk to people and property. They should do this, and manage any residual risk, by:

a) Applying the sequential test and then, if necessary, the exception test as set out below;

b) Safeguarding land from development that is required, or likely to be required, for current or future flood management;

c) Using opportunities provided by new development to reduce the causes and impacts of flooding (where appropriate through the use of natural flood management techniques); and

d) Where Climate Change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to relocate development, including housing, to more sustainable locations."

4.25 Paragraph 158 of the NPPF follows this up by stating that "Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding.… The sequential approach should be used in areas known to be at risk now or in the future from any form of flooding."

4.26 National Policy is clear in the importance of steering new development away from areas at risk of flooding. Indeed, paragraph 158 is clear in its directive that development should not be allocated or permitted where there are reasonably available sites in areas with a lower risk of flooding.

4.27 This is not to say that development within areas at risk of flooding is always unacceptable and indeed there may be good reasons for doing so, say, where there are clear sustainability benefits or a lack of land in areas at lower risks of flooding. However, as a general principle, sites in Flood Zone 1 should take precedence over sites in Flood Zones 2 and 3 when it comes to identifying sites for development.

4.28 When applying the sequential approach through the Local Plan process, we would stress that a site's Green Belt designation should not be something which dictates whether it is reasonably available or not. This is because the Local Plan process allows for revisions to Green Belt boundaries where there are exceptional circumstances for doing so.

4.29 This is different to the very special circumstances that need to be demonstrated under the development management process in order to allow development in the Green Belt and that would otherwise allow a site to be discounted within any sequential assessment.

4.30 Indeed, the need to avoid areas of flood risk can be a contributing factor to demonstrating the exceptional circumstances for releasing land from the Green Belt as there are sound environmental and social reasons for doing so. The judgment in the 2015 court case Calverton Parish Council v Greater Nottingham Council & Others (EWHC 1078) identifies five matters to consider when assessing whether exceptional circumstances are present. One such identified circumstance was the "consequent difficulties in securing sustainable development without impinging on the Green Belt."

4.31 The development of greenfield sites in areas of flood risk is inherently unsustainable given that it exacerbates the potential impacts of Climate Change and increases the risks to human life and property. Assuming that the development needs of the District could not be met on sustainable locations outside the Green Belt on land entirely within Flood Zone 1, then this would constitute an exceptional circumstance that would justify development in the Green Belt.

4.32 In short, National Policy is clear in that development should be steered away from areas of high flood risk. Key reasons for this are to mitigate the potential impacts of Climate Change and minimise the risk to human life and property. The need to avoid areas of flood risk would be a contributing factor to justifying the release of Green Belt sites in sustainable locations.

3. Protect and enhance ecological, landscape and heritage designations and their settings.

4.33 Agree. The level of protection afforded should be proportionate to their relative significance, as dictated by the NPPF and relevant legislation. For all potential strategic allocations, the public benefits may need to be weighed against any harms through the Sustainability Appraisal process.

4. Protect and enhance the function and connectivity of our Green Infrastructure and Nature Recovery Networks.

4.34 Agree. As above, the level of protection afforded should be proportionate and appropriate to the significance of said asset. Proposals should also be considered on a wholistic basis, with the net gains that could be facilitated through the loss of certain features that may be necessary to enable development to come forward.

5. Plan for a better balance between local jobs and resident workers in our communities.

4.35 Agree. The need to commute to and from work is unavoidable for many and this is often done by the private motor vehicle. Locating development in close proximity to areas with good access to existing employment centres and/or delivering employment alongside new residential development can help to promote the use of walking, cycling and Public Transport as an alternative to the private motor vehicle.

4.36 There are also social benefits in achieving a good balance between local jobs and resident workers. Offering alternative (and cheaper) options to the private motor vehicle will improve accessibility to employment for many people, some of whom may not own a car.

4.37 Intuitively, development at certain rural villages would appear to run against this principle. However, this does not mean that development should not be directed towards villages where reliance on the private motor vehicle is likely to remain relatively high for the reasons set out above.

4.38 Furthermore, there has been a significant shift in working and travel patterns as a result of the pandemic with many working from home on a permanent or semi-permanent basis. As such, the sustainability drawbacks to development at rural settlements have been slightly diminished, especially where digital connectivity is good.

6. Ensuring that we protect a ‘sense of place and character’ when we plan for new development.

4.39 We support this principle in the sense that the protection of place and character should be sought where the current sense of place and character is worth preserving. Opportunities to enhance, improve and create a new sense of place and character should also be explored where the context dictates.

Do you think we have missed any key, initial guiding principles?

4.40 Whilst we agree with the guiding principles as a sound way in which to identify sustainable locations for growth, the absence of 'deliverability' as a principle is of some concern. As has been alluded to in the Phase 1 document, deliverability issues have led to the Council being unable to demonstrate a robust housing land supply in recent years. This has led to speculative development at many of the non-Green Belt towns and villages coming forward in recent years. Again, whilst this development is not fundamentally unsustainable in nature, it sits outside of an agreed framework which would most likely deliver more sustainable development in the round.

4.41 Deliverability, or rather a failure to deliver the housing to meet the District's needs, also has significant social and economic consequences which we have touched on above and are considered in the latest SA.

4.42 We accept that deliverability considerations may not be appropriate for the purposes of identifying potential locations for development. However, it should certainly form part of any site sifting exercise that may be undertaken, once these options have been identified.

4.43 We would suggest a deliverability metric be applied to all options considered and those considered to be at significant risk of delivery, should be screened out at an appropriate stage.
13 May 2021 17:52
Persimmon Homes Severn Valley Please see attached document.

5. Developing a growth Strategy: potential guiding principles (Section 5):

5.1 This section of the Plan seeks to identify six guiding principles for assessing the suitability of different locations to accommodate new growth. We recognise that these are “initial ideas” and would offer what we hope to be constructive comments of the principles that have been identified.

Guiding Principle 1: Locate new homes, jobs or settlements in places where key services and facilities are easily accessed by walking and cycling or effective Public Transport, or alternatively in locations where key services and facilities are capable of being provided as part of the new development.

5.2 We support this principal as being key to the consideration and assessment of alternative locations for accommodating growth. Indeed, such an approach lies at the heart of those Buildings Blocks aimed at optimising opportunities within urban areas as well as sustainable growth around the market towns.

5.3 We note, however, that much of the commentary on this guiding principle is focussed on entirely new services and facilities provided as part of a development including the statement “…. the larger the scale of growth proposed, the more local services and facilities, including opportunities for local employment would be expected to be provided.”

5.4 Whilst we do not disagree with such a statement, the Plan should also highlight the desirability of locating development where it is accessible to existing services and facilities which can be more sustainable than having to provide entirely new facilities. The Plan should also reference the fact that new development can benefit and support existing services and facilities, both directly and indirectly, including through increased patronage.

5.5 Finally we note and support the Diagram on page 68 “Accessing Services and Facilities” which demonstrates the high levels of connectivity of Chipping Sodbury/Yate.

Guiding Principle 2: Sequential approach to building on areas at a high risk of flooding.

5.6 This principle is supported not least because it effectively repeats National Policy Guidance. However, we believe that it should acknowledge that, in some cases, only a small part of a much larger site may be affected by flood issues and therefore, with appropriate design (i.e. avoiding areas that may be prone to flooding) and appropriate mitigation, such sites should not be prevented from coming forward for development.

5.7 We further suggest that this principle should acknowledge that new development can have significant benefits for existing properties that are already subject to flooding. For example, work undertaken in support of the land at East Chipping Sodbury, in association with the Environment Agency, has concluded that the development of the site offers the opportunity to reduce existing flooding in Chipping Sodbury including properties on St. John’s Way. This is entirely consistent with National Planning Policy which states that Local Planning Authorities should use:

“Opportunities provided by new development to reduce the causes and impacts of flooding (where appropriate through the use of natural flood management techniques).…” (NPPF para 157 (c)).

Guiding Principle 3: Protect and enhance ecological, landscape and heritage designations and their settings.

5.8 We support the aspiration of this Guiding Principle.

Guiding Principle 4: Protect and enhance the function and connectivity of our Green Infrastructure and Nature Recovery Networks.

5.9 We generally support the aspirations of this Guiding Principle.

Guiding Principle 5: Plan for a better balance between local jobs and resident workers in our communities.

5.10 We support the aspiration of this Guiding Principle which also enforces the need to identify locations for new homes which have access, including by cycling, walking and Public Transport, to employment opportunities. As stated previously, this supports the allocation of land at East Chipping Sodbury.

Guiding Principle 6: Ensuring that we protect a ‘sense of place and character’ when we plan for new development.

5.11 We support the aspiration of this Guiding Principle. Land at East Chipping Sodbury offers the opportunity for a high quality new residential area that integrates well with the existing community as well as accessing and supporting existing services in the Town and in Yate. Further, and notwithstanding the physical connectivity of the Town with Yate, development at East of Chipping Sodbury will ensure the retention of the historic character of Chipping Sodbury.
11 May 2021 18:35
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