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.

1. The population of a settlement is worth looking at but only as a proxy for other indicators of sustainability such as the existing population;

2. The level of growth in recent years is not in itself considered to be a helpful indicator. The fact that there may not have been much growth in certain areas over recent years (as in the case of Easter Compton) means these locations may well now warrant the need for further new development;

3. The availability of infrastructure is important, and the Plan should look not just at capacity but also the benefits and practicalities of improving these networks (in the case of Easter Compton we would point to the potential for existing and improved Public Transport benefits);

4. Access to supporting services and facilities is very important and existing policy has helped in this respect, however it is also pertinent to look at proximity to higher order facilities and strategic employment provision in particular (the strategic advantages of Easter Compton are set out elsewhere in these representations);

5. It is relevant to consider the designations identified within the consultation document but only in a way that reflects the approach of the NPPF and having regard to the objective of contributing to the achievement of sustainable development (we have set out elsewhere in the approach necessary in respect of the Green Belt).
01 Jun 2021 12:24
Hannah Saunders - Dodington Pa… Pages 113 to 136 – Creating sustainable rural villages and settlements:

• Members note that our ‘rural area’ South Ward of Dodington isn’t included…. hamlets (Codrington, Dodington and Wapley). It should be noted that we have had instances where Planning has not been allowed (or has been questioned) because the hamlets lie in Green Belt. The plans haven’t been untoward or affected others…. and have meant that parents can stay on site (annexes, etc)…. whilst appreciate the Green Belt needs to be protected – sense needs to prevail in some instances.

• Members would mention again – connectivity of Rural areas to transport hubs and towns. These areas used to benefit from mobile Libraries, etc but this service has been stopped and Covid–19 has highlighted how isolated some residents feel. Some rural villages don’t have a bus service at all – and have to rely on volunteers, family members or private transport/taxis.

• When people want to downsize in rural areas this isn’t always possible…. they have a large family home – but need something smaller. They don’t want to move out of village…. this sort of development needs to be considered on an ad hoc basis.

• On a similar note – if children want to move out of home – but stay in village – often they can’t afford to – because of lack/cost of housing and job opportunities…. and no connectivity.
25 May 2021 16:13
Waddeton Park Ltd - Land at Hi… 58. As examined above, the exploration of growth at villages is supported, but a one-size-fits-all approach is not appropriate for South Gloucestershire. Some villages like Winterbourne which are close to Bristol provide a greater opportunity to support the Climate Change Emergency through increased, sustainable growth, whilst other outlying villages such as Charfield and Falfield simply increase commuter distances travelled to the Greater Bristol conurbation and thus the impact on Climate Change.

59. Whilst the re-opening of Charfield Station which provides an opportunity for local modal shift is generally supported, Appendix 2 shows that many people who commute into Bristol City do not work near one of the railway stations in the city. This brings into question the convenience and usability of the travel mode if commuters have the inconvenience of multimodal trips which then become time consuming. As presented earlier the current use of this mode accounts for 2% of commuting. As such we would like to see the evidence base for the emerging Plan being more comprehensive in its assessment of different journeys from specific settlements and their convenience when related to the range of destinations within Greater Bristol. What Appendix 2 shows is that even with improved modal shift and self-containment, many settlements outside the Green Belt will continue to perform worse than Winterbourne in terms of Carbon tonnes per annum resulting from travel to work.

60. We expect a Plan which genuinely seeks to address Climate Change, and which will focus on meeting local housing growth at settlements which have the capacity for increased growth at the most sustainable villages around the Bristol Fringe to be coupled with a realistic focus on the Urban Lifestyle potential of the North and East Fringe.
17 May 2021 18:40
Ivywell Capital (IC) • Development at rural villages is also essential to maintain their vitality and viability. New housing can provide opportunities for elderly residents to downsize, younger people to get on the housing ladder, or young families to move in to ensure a diverse population is maintained which can support existing services and facilities (e.g. young families can support the need for existing Primary Schools).

• New development at rural villages can also deliver affordable housing which is important, especially in rural areas where house prices are relatively high and small starter homes are in short supply.

• The Green Belt constraint around certain villages has exacerbated this issue significantly as speculative development has been prevented even where the housing land supply position has been deficient.

• There are significant benefits associated with facilitating modest development at rural villages and welcome the Council's indication that this will be explored by the Local Plan.

5.1 The approach to areas of flood risk is considered appropriate. We have discussed this in more detail above, however, our position is that development in areas of higher flood risk is inherently less sustainable than development in areas of lower flood risk. The former should, therefore, be avoided where appropriate alternatives are available as per the guidance in the NPPF and PPG.

5.2 With regard to AONBs, we support the exploration of a strategy to support growth in rural areas in the interests of maintaining the vitality and viability of these communities and combating affordability issues. However, we note that the need to protect valued landscapes means that development in these locations will need to be relatively small scale.

5.3 With regard to rural communities in the Green Belt, we agree that the first stage is to establish whether the District's development needs can be met without impinging upon the Green Belt, or if there are exceptional circumstances that would justify its release.

5.4 Once this is established, the question is whether their development needs/requirements can be met through the exceptions set out in paragraph 145 of the NPPF (limited infilling, redevelopment of Brownfield sites, rural exceptions sites for affordable housing etc) or if this would dictate a more direct approach (e.g. formal allocations).

5.5 The Phase 1 document suggests that the housing requirement, coupled with constraints at villages beyond the Green Belt, will likely mean a proportion of growth needs to be directed to settlements within the Green Belt as well. This is supported by the Sustainability Appraisal which has indicated clear sustainability benefits associated with directing growth toward villages within the Green Belt (table 4.7 of the SA). This is a welcome start; however, we note that a flaw of the JSP and a common pitfall of other Local Plans is the failure to provide a robust assessment in support of the exceptional circumstances being demonstrated (e.g. Ashfield District Council and Amber Valley Borough Council fell at the Examination in Public stage due to the poor quality of the evidence in respect of Green Belt release). We would suggest a dedicated topic paper be prepared in support of the Plan if, as we expect, Green Belt releases be required to support the development needs of the District.

5.6 We agree that the new Local Plan will need to explore the possibility of growth at rural settlements in the Green Belt for a range of development scales to underpin housing delivery from the larger strategic sites that will also be necessary to meet the overall housing requirements.

5.7 This will, ultimately, be dictated in part by the scale of the housing requirement and reliance that will be placed on strategic sites. A significant advantage of a dispersed approach to housing distribution is that delivery is likely to be less of an issue. However, we acknowledge that there are trade-offs with achieving wider sustainability objectives and so an appropriate balance will need to be struck.

5.8 The obvious advantage for settlements in the Green Belt is that they tend to be better related to the Bristol Urban Fringe and market towns of Yate, Thornbury and Chipping Sodbury where services, facilities and employment opportunities are more readily accessible. There is, therefore, greater potential for development to achieve the sustainability objectives set out in the Phase 1 document through development at rural settlements.

5.9 There are a handful of ways in which the Council could manage development at the rural villages; however, we would support the identification of allocations at settlements, either through this Plan or a subsequent site allocations plan. This is more important for the Green Belt villages given that boundaries can only be altered by Local Plans. This may be the preferred approach in the interests of ensuring delivery at these settlements can come forward earlier in the Plan period.

5.10 Alternatively, the process of identifying site allocations could be deferred to the Neighbourhood Plan (NHP) process, at least for certain Parishes where these are being progressed. However, it will be important for the Local Plan to establish what the requirement for these areas would be and establish the exceptional circumstances necessary to justify development within the identified Parishes. A view can be taken at a later date as to whether a Site Allocations Plan would need to be progressed if insufficient progress has been made on any emerging NHPs.

Do you have any comments on our proposed approach to investigate an appropriate level of growth in our rural villages and settlements?

5.11 We support the principle of seeking to ensure that development at the rural villages is Plan-led in light of the level of speculative development that has come forward at them in recent years.

5.12 Whilst strategic levels of development will be required to sustainably meet the bulk of the Council's housing requirement, development at villages where large-scale development is not possible will still be required to support the vitality and viability of those settlements and address affordability issues.

5.13 In terms of the approach to investigating the appropriate levels of growth that should come forward at the rural villages, the two options are appropriate starting points and will need to be subject to an appropriate Sustainability Appraisal to establish which should ultimately be pursued. The approach may then need to be refined in terms of identifying which rural settlements in the Green Belt should be prioritised based on the application of the guiding principles outlined within the consultation document.

5.14 Indeed, we would note that the Phase 1 document is already suggesting that non-strategic growth at Green Belt settlements would have sustainability benefits over purely pursuing growth at non-Green Belt locations. This, coupled with the overall housing requirement will likely constitute the exceptional circumstances required to justify the release of Green Belt land for development. As such, we consider that Option 2 will need to be pursued and is supported on this basis.
17 May 2021 15:38
Bristol and England Properties… 5.1 The approach to areas of flood risk is considered appropriate. We have discussed this in more detail above, however, our position is that development in areas of higher flood risk is inherently less sustainable than development in areas of lower flood risk. The former should, therefore, be avoided where appropriate alternatives are available as per the guidance in the NPPF and PPG.

5.2 With regard to AONBs, we support the exploration of a strategy to support growth in rural areas in the interests of maintaining the vitality and viability of these communities and combating affordability issues. However, we note that the need to protect valued landscapes means that development in these locations will need to be relatively small scale.

5.3 With regard to rural communities in the Green Belt, we agree that the first stage is to establish whether the District's development needs can be met without impinging upon the Green Belt, or if there are exceptional circumstances that would justify its release.

5.4 The guiding principles for identifying potential growth locations strongly indicates that land around the Bristol urban fringe, Yate and key transit routes (e.g. Frampton Cotterell and Coalpit Heath) have clear sustainability benefits over development in non-Green Belt locations that would justify their release.

5.5 With regard to smaller settlements, the question is whether their development needs/requirements can be met through the exceptions set out in paragraph 145 of the NPPF (limited infilling, redevelopment of Brownfield sites, rural exceptions sites for affordable housing etc) or if this would dictate a more direct approach (e.g. formal allocations).

5.6 The Phase 1 document suggests that the housing requirement, coupled with constraints at villages beyond the Green Belt, will likely mean a proportion of growth needs to be directed to settlements within the Green Belt as well. This is supported by the Sustainability Appraisal which has indicated clear sustainability benefits associated with directing growth toward villages within the Green Belt (table 4.7 of the SA). This is a welcome start; however, we note that a flaw of the JSP and a common pitfall of other Local Plans is the failure to provide a robust assessment in support of the exceptional circumstances being demonstrated (e.g. Ashfield District Council and Amber Valley Borough Council fell at the Examination in Public stage due to the poor quality of the evidence in respect of Green Belt release). We would suggest a dedicated topic paper be prepared in support of the Plan if, as we expect, Green Belt releases be required to support the development needs of the District.

5.7 We agree that the new Local Plan will need to explore the possibility of growth at rural settlements in the Green Belt for a range of development scales to underpin housing delivery from the larger strategic sites that will also be necessary to meet the overall housing requirements.

5.8 This will, ultimately, be dictated in part by the scale of the housing requirement and reliance that will be placed on strategic sites. A significant advantage of a dispersed approach to housing distribution is that delivery is likely to be less of an issue. However, we acknowledge that there are trade-offs with achieving wider sustainability objectives and so an appropriate balance will need to be struck.

5.9 The obvious advantage for settlements in the Green Belt is that they tend to be better related to the Bristol Urban Fringe and market towns of Yate, Thornbury and Chipping Sodbury where services, facilities and employment opportunities are more readily accessible. There is, therefore, greater potential for development to achieve the sustainability objectives set out in the Phase 1 document through development at rural settlements.

5.10 There are a handful of ways in which the Council could manage development at the rural villages; however, we would support the identification of allocations at settlements, either through this Plan or a subsequent site allocations plan. This is more important for the Green Belt villages given that boundaries can only be altered by Local Plans. This may be the preferred approach in the interests of ensuring delivery at these settlements can come forward earlier in the Plan period.

5.11 Alternatively, the process of identifying site allocations could be deferred to the Neighbourhood Plan (NHP) process, at least for certain Parishes where these are being progressed. However, it will be important for the Local Plan to establish what the requirement for these areas would be and establish the exceptional circumstances necessary to justify development within the identified Parishes. A view can be taken at a later date as to whether a Site Allocations Plan would need to be progressed if insufficient progress has been made on any emerging NHPs.
17 May 2021 10:52
South West Housing Association… 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. 14 May 2021 19:19
Newland Homes - Land at Aust Road 5.1 The approach to areas of flood risk is considered appropriate. We have discussed this in more detail above, however, our position is that development in areas of higher flood risk is inherently less sustainable than development in areas of lower flood risk. The former should, therefore, be avoided where appropriate alternatives are available as per the guidance in the NPPF and PPG.

5.2 Regarding AONBs, we support the exploration of a strategy to deliver growth in rural areas in the interests of maintaining the vitality and viability of these communities and combating affordability issues. However, we note that the need to protect valued landscapes means that development in these locations will need to be relatively small scale.

5.3 With regard to rural communities in the Green Belt, we agree that the first stage is to establish whether the District's development needs can be met without impinging upon the Green Belt, or if there are exceptional circumstances that would justify its release.

5.4 The guiding principles for identifying potential growth locations strongly indicates that land around the Bristol urban fringe, Yate and key transit routes (e.g. Coalpit Heath and Frampton Cotterell) have clear sustainability benefits over development in non-Green Belt locations that would justify their release.

5.5 With regard to smaller settlements, the question is whether their development needs/requirements can be met through the exceptions set out in paragraph 145 of the NPPF (limited infilling, redevelopment of Brownfield sites, rural exceptions sites for affordable housing etc) or if this would dictate a more direct approach (e.g. formal allocations).

5.6 The Phase 1 document suggests that the housing requirement, coupled with constraints at villages beyond the Green Belt, will likely mean a proportion of growth needs to be directed to settlements within the Green Belt as well. This is supported by the Sustainability Appraisal which has indicated clear benefits associated with directing growth toward villages within the Green Belt (table 4.7 of the SA). This is a welcome start; however, we note that a flaw of the JSP and a common pitfall of other Local Plans is the failure to provide a robust assessment in support of the exceptional circumstances being demonstrated (e.g. Ashfield District Council and Amber Valley Borough Council fell at the Examination in Public stage due to the poor quality of the evidence in respect of Green Belt release). We would suggest a dedicated topic paper be prepared in support of the Plan if, as we expect, Green Belt releases be required to support the development needs of the District.

5.7 We agree that the new Local Plan will need to explore the possibility of growth at rural settlements in the Green Belt for a range of development scales to underpin housing delivery from the larger strategic sites that will also be necessary to meet the overall housing requirements.

5.8 This will, ultimately, be dictated in part by the scale of the housing requirement and reliance that will be placed on strategic sites. A significant advantage of a dispersed approach to housing distribution is that delivery is likely to be less of an issue. However, we acknowledge that there are trade-offs with achieving wider sustainability objectives and so an appropriate balance will need to be struck.

5.9 The obvious advantage for settlements in the Green Belt is that they tend to be better related to the Bristol Urban Fringe and market towns of Yate, Thornbury and Chipping Sodbury where services, facilities and employment opportunities are more readily accessible. There is, therefore, greater potential for development to achieve the sustainability objectives set out in the Phase 1 document through development at rural settlements.

5.10 There are a handful of ways in which the Council could manage development at the rural villages; however, we would support the identification of allocations at settlements, either through this Plan or a subsequent site allocations plan. This is more important for the Green Belt villages given that boundaries can only be altered by Local Plans. This may be the preferred approach in the interests of ensuring delivery at these settlements can come forward earlier in the Plan period.

5.11 Alternatively, the process of identifying site allocations could be deferred to the Neighbourhood Plan (NHP) process, at least for certain Parishes where these are being progressed. However, it will be important for the Local Plan to establish what the requirement for these areas would be and establish the exceptional circumstances necessary to justify development within the identified Parishes. A view can be taken at a later date as to whether a Site Allocations Plan would need to be progressed if insufficient progress has been made on any emerging NHPs.

Do you have any comments on our proposed approach to investigate an appropriate level of growth in our rural villages and settlements?

5.12 We support the principle of seeking to ensure that development at the rural villages is Plan-led in light of the level of speculative development that has come forward at them in recent years.

5.13 Whilst strategic levels of development will be required to sustainably meet the bulk of the Council's housing requirement, development at villages where large-scale development is not possible will still be required to support the vitality and viability of those settlements and address affordability issues.

5.14 In terms of the approach to investigating the appropriate levels of growth that should come forward at the rural villages, the two options are appropriate starting points and will need to be subject to an appropriate Sustainability Appraisal to establish which should ultimately be pursued. The approach may then need to be refined in terms of identifying which rural settlements in the Green Belt should be prioritised based on the application of the guiding principles outlined within the consultation document.
14 May 2021 17:12
Newland Homes - Land West of T… 5.1 The approach to areas of flood risk is considered appropriate. We have discussed this in more detail above, however, our position is that development in areas of higher flood risk is inherently less sustainable than development in areas of lower flood risk. The former should, therefore, be avoided where appropriate alternatives are available as per the guidance in the NPPF and PPG.

5.2 Regarding AONBs, we support the exploration of a strategy to deliver growth in rural areas in the interests of maintaining the vitality and viability of these communities and combating affordability issues. However, we note that the need to protect valued landscapes means that development in these locations will need to be relatively small scale.

5.3 With regard to rural communities in the Green Belt, we agree that the first stage is to establish whether the district's development needs can be met without impinging upon the Green Belt, or if there are exceptional circumstances that would justify its release.

5.4 The guiding principles for identifying potential growth locations strongly indicates that land around the Bristol urban fringe, Yate and key transit routes (e.g. Coalpit Heath and Frampton Cotterell) have clear sustainability benefits over development in non-Green Belt locations that would justify their release.

5.5 With regard to smaller settlements, the question is whether their development needs/requirements can be met through the exceptions set out in paragraph 145 of the NPPF (limited infilling, redevelopment of Brownfield sites, rural exceptions sites for affordable housing etc) or if this would dictate a more direct approach (e.g. formal allocations).

5.6 The Phase 1 document suggests that the housing requirement, coupled with constraints at villages beyond the Green Belt, will likely mean a proportion of growth needs to be directed to settlements within the Green Belt as well. This is supported by the Sustainability Appraisal which has indicated clear benefits associated with directing growth toward villages within the Green Belt (table 4.7 of the SA). This is a welcome start; however, we note that a flaw of the JSP and a common pitfall of other Local Plans is the failure to provide a robust assessment in support of the exceptional circumstances being demonstrated (e.g. Ashfield District Council and Amber Valley Borough Council fell at the Examination in Public stage due to the poor quality of the evidence in respect of Green Belt release). We would suggest a dedicated topic paper be prepared in support of the Plan if, as we expect, Green Belt releases be required to support the development needs of the District.

5.7 We agree that the new Local Plan will need to explore the possibility of growth at rural settlements in the Green Belt for a range of development scales to underpin housing delivery from the larger strategic sites that will also be necessary to meet the overall housing requirements.

5.8 This will, ultimately, be dictated in part by the scale of the housing requirement and reliance that will be placed on strategic sites. A significant advantage of a dispersed approach to housing distribution is that delivery is likely to be less of an issue. However, we acknowledge that there are trade-offs with achieving wider sustainability objectives and so an appropriate balance will need to be struck.

5.9 The obvious advantage for settlements in the Green Belt is that they tend to be better related to the Bristol Urban Fringe and market towns of Yate, Thornbury and Chipping Sodbury where services, facilities and employment opportunities are more readily accessible. There is, therefore, greater potential for development to achieve the sustainability objectives set out in the Phase 1 document through development at rural settlements.

5.10 There are a handful of ways in which the Council could manage development at the rural villages; however, we would support the identification of allocations at settlements, either through this Plan or a subsequent site allocations plan. This is more important for the Green Belt villages given that boundaries can only be altered by Local Plans. This may be the preferred approach in the interests of ensuring delivery at these settlements can come forward earlier in the Plan period.

5.11 Alternatively, the process of identifying site allocations could be deferred to the Neighbourhood Plan (NHP) process, at least for certain Parishes where these are being progressed. However, it will be important for the Local Plan to establish what the requirement for these areas would be and establish the exceptional circumstances necessary to justify development within the identified Parishes. A view can be taken at a later date as to whether a Site Allocations Plan would need to be progressed if insufficient progress has been made on any emerging NHPs.

5.12 We support the principle of seeking to ensure that development at the rural villages is Plan-led in light of the level of speculative development that has come forward at them in recent years.

5.13 Whilst strategic levels of development will be required to sustainably meet the bulk of the Council's housing requirement, development at villages where large-scale development is not possible will still be required to support the vitality and viability of those settlements and address affordability issues.

5.14 In terms of the approach to investigating the appropriate levels of growth that should come forward at the rural villages, the two options are appropriate starting points and will need to be subject to an appropriate Sustainability Appraisal to establish which should ultimately be pursued. The approach may then need to be refined in terms of identifying which rural settlements in the Green Belt should be prioritised based on the application of the guiding principles outlined within the consultation document.
13 May 2021 17:52
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