South Gloucestershire New Local Plan Phase 1 Responses

Local Plan 2020

List of answers to the specified question
NameResponseDate
Redcliffe Homes No comments. 01 Jun 2021 13:16
Waddeton Park Ltd - Land at Hi… 65. It is important that the emerging policy is consistent with the emerging SDS with regard to Climate Change and that the proposed separate guiding technical documentation is published for scrutiny at the same time.

66. SGC’s pledge to enable Carbon neutrality and the commitment to use the emerging Plan to aid this process is broadly supported. Whilst it is possible to improve the Carbon footprint of sites, buildings and their uses in a universal manner (as suggested by the emerging policy framework), this does not address the impact that travel patterns have on Carbon neutrality and as has been said throughout, we would welcome a Plan with a Spatial Strategy that also seeks this.

67. The Office for National Statistics (Sept 2019 release) cites road transport as contributing 20% to Greenhouse Gas emissions in the UK. The ability to reach net zero by 2030 relies on an immediate implementation of a Spatial Strategy which reduces travel distances and can engender a change in the mode of travel as a result. This is 6% above what SGC’s Carbon Pledge suggests and in our opinion is a material part of reducing the impact of Climate Change that the development plan can address through its Spatial Strategy.

68. Encouraging development through the Plan-led system in sustainable locations which minimise both trip lengths and encourage modal shift is something that this Core Strategy Review should address now, to allow the benefit to be received by 2030 (9 years’ time) when the Council is seeking to have reached zero net Carbon. The reason it needs to be addressed now is that the average lead-in time of larger development can be as long as 5 years and that would only leave 4 more years to deliver the transition. Sites at the scale of Hicks Common Road (up to 300 dwellings) would be completed well within the timeframe and would show a measurable response to the Climate Change.

69. In the context of proper spatial planning, one of the most important aspects for the Plan to address is the balance between maintaining some parts of the inner Green Belt as a protective policy and allowing development in locations such as Winterbourne which will address the declared Climate Change Emergency.

70. It is suggested that as part of the evidence base to support the emerging Plan and the declared Climate Change emergency, further detailed research is undertaken about the impacts of where development is located and how, for example, the creation of mixed-use communities at the right scale can provide a substantial positive response to Climate Change. This is something the Sustainability Appraisal has not explored yet.

71. We would welcome the opportunity to work with SGC to respond to the declared Climate Change emergency.

72. We are, however, concerned about the level of prescription in the current proposed policy wording. Criteria a - g for example, could be an advisory list for individual site developers to refer to in demonstrating how Climate Change is addressed. Over prescription in the policy can stifle innovation and delivery in a sector that is driven by change.

73. Regarding the Adaptation measures set out in the supporting text a - g, it is important that these are presented as guiding principles rather than a list of fixed requirements. This is because not all developments, such as urban intensification for example, may be able to support local food production whereas other locations such as our client’s land can.
17 May 2021 18:40
Ivywell Capital (IC) 6.3 We generally support the purpose of this policy; however, there are concerns about its clarity in terms of what exactly will be required of developers. The policy wording requires the 'minimisation' of impacts and 'reductions' in Greenhouse Gas emissions, but does not establish a clear dividing line between what exactly needs to be achieved for proposals to be acceptable.

6.4 The inference is that new development needs to be Carbon neutral given that this is an overarching aim for Council. However, this term needs to be defined explicitly so there is no ambiguity about what new development needs to achieve.

6.5 If the intention is for this to be linked to the 'Energy Management in New Development' Policy, this should be made explicit or the two policies should be combined.
17 May 2021 15:38
Bristol and England Properties… 6.3 We generally support the purpose of this policy; however, there are concerns about its clarity in terms of what exactly will be required of developers. The policy wording requires the 'minimisation' of impacts and 'reductions' in Greenhouse Gas emissions, but does not establish a clear dividing line between what exactly needs to be achieved for proposals to be acceptable.

6.4 The inference is that new development needs to be Carbon neutral given that this is an overarching aim for Council. However, this term needs to be defined explicitly so there is no ambiguity about what new development needs to achieve.

6.5 If the intention is for this to be linked to the 'Energy Management in New Development' Policy, this should be made explicit or the two policies should be combined.
17 May 2021 10:52
South West Housing Association… There are a number of working draft policies at Appendix 2 which concern Climate Change mitigation, energy management and electric car charging. We support these draft policies where the Council can show that they have been robustly viability tested. While these policies are essential for futureproofing our communities, they should not restrict the delivery of much needed affordable housing in South Gloucestershire, especially as affordability remains a key issue for the Council. 14 May 2021 19:19
Newland Homes - Land at Aust Road 6.3 We generally support the purpose of this policy; however, there are concerns about its clarity in terms of what exactly will be required of developers. The policy wording requires the 'minimisation' of impacts and 'reductions' in Greenhouse Gas emissions, but does not establish a clear dividing line between what exactly needs to be achieved for proposals to be acceptable.

6.4 The inference is that new development needs to be Carbon neutral given that this is an overarching aim for Council. However, this term needs to be defined explicitly so there is no ambiguity about what new development needs to achieve.

6.5 If the intention is for this to be linked to the 'Energy Management in New Development' Policy, this should be made explicit or the two policies should be combined.
14 May 2021 17:12
Newland Homes - Land West of T… 6.3 We generally support the purpose of this policy; however, there are concerns about its clarity in terms of what exactly will be required of developers. The policy wording requires the 'minimisation' of impacts and 'reductions' in Greenhouse Gas emissions, but does not establish a clear dividing line between what exactly needs to be achieved for proposals to be acceptable.

6.4 The inference is that new development needs to be Carbon neutral given that this is an overarching aim for Council. However, this term needs to be defined explicitly so there is no ambiguity about what new development needs to achieve.

6.5 If the intention is for this to be linked to the 'Energy Management in New Development' Policy, this should be made explicit or the two policies should be combined.
13 May 2021 17:52
Persimmon Homes Severn Valley Please see attached document.

New Policy: Climate Change and Adaptation:

6.4 We generally support the approach of this policy. We believe that one of the key aspects of the policy is that set out in part (b) of the supporting text relating to ensuring that development is located in areas where the need to travel is minimised and opportunities for utilising sustainable transport are optimised.

6.5 We are also support measures to reduce Greenhouse Gas emissions and improve energy efficiency. However, the policy should be clear that proposals will considered on their individual merits including taking into account factors such as the availability of technology and viability. It is important, however, that the Plan is consistent (and does not attempt to exceed) the requirements and provisions set out in Building Regulations.
11 May 2021 18:35
Strongvox Homes Climate Change Mitigation and Adaptation:

6.3 Strongvox Homes support the purpose of this policy; however, there are concerns about its clarity in terms of what exactly will be required of developers. The policy wording requires the 'minimisation' of impacts and 'reductions' in Greenhouse Gas emissions, but does not establish a clear dividing line between what exactly needs to be achieved for proposals to be acceptable.

6.4 The inference is that new development needs to be Carbon neutral given that this is an overarching aim for Council. However, this term needs to be defined explicitly so there is no ambiguity about what new development needs to achieve.

6.5 If the intention is for this to be linked to the 'Energy Management in New Development' Policy, this should be made explicit or the two policies should be combined.
11 May 2021 18:08
Progress Land Ltd No. 11 May 2021 13:45
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