South Gloucestershire New Local Plan Phase 1 Responses

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Response #918788

Response #918788
From ATA Estates (Longwell Green) L…
Agent Ian Jewson - Walsingham Planni…
Date Started: 06 Apr 2021 18:34. Last modified: 26 May 2021 10:53
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Information on the Local Plan

 

To view the Phase 1 Issues and Approaches document including the sections referred to in this questionnaire, please visit www.southglos.gov.uk/LocalPlan2020.

1: Understanding who is responding

Please help us understand the type of groups and people that are responding and engaging with the preparation of our new Local Plan, by choosing which one of the following stakeholder groups you best represent.

You must choose one option to be able to submit your response.

You must provide an answer to this question.

Developer, land agent or site promoter
If other, please state:
«No response»

2: Issues

We have set out 55 issues which our Local Plan will need to consider.

The 55 issues are set out in this section of our document.  

Do you agree that these are the right issues for our plan to consider?

  • Yes
  • No
  • Don't know

3: Issues

Would you like to comment on any of the issues or add new issues? Please note the name of the issue in your comments, or tell us what additional issues you think our plan should consider.

Issues:

Generally, the 55 issues set out in the new Local Plan provides a good range. The list should not however be considered exhaustive. It may well be that other issues should be added as the Local Plan process moves forward.

The 55 Issues:

We would raise the following points of particular note:

24. Green Belt:

As set out later in these representations it is considered that land to the East of Bristol in appropriate sustainable locations such as on our client’s land should be released from the Green Belt.

29. Affordable Housing:

The recognition that South Gloucestershire has a significant affordability gap is welcomed. Positive planning policies are required through this Plan review to address this. This has been a long-standing issue for the area as previously highlighted by paragraph 3.15 of the Adopted Core Strategy (2013) which states that ‘Despite the housing market downturn of 2008 and 2009 and reduced access to mortgage finance, house prices have risen in South Gloucestershire compared to incomes over the last 10 years.’

32. Issues with housing delivery on large scale sites:

There are a wide range of factors which affect whether predictions of delivery rates can be achieved. This is often not the fault of the development industry but due to delays and complexities of the decision-making process. It is therefore imperative that the new Local Plan includes suitable flexibility to ensure a suitable supply of housing is maintained without reliance on large scale speculative developments.

48. School capacity and access:

The provision of well designed education facilities delivered in a timely manner is an important aspect of the new Local Plan and should be carefully considered alongside the overall Plan strategy.

4: Priorities

Do you agree with the potential priorities?

  • Yes
  • No
  • Don't know

5: Priorities

Do you have any comments on the potential priorities?

It is not clear whether the priorities are intended to have equal importance or are listed in priority order. If it is the latter, then this would suggest a focus on Carbon reductions and the climate emergency over future housing and business needs and should be clearly stated. Ultimately, economic conditions will be a key factor in achieving future prosperity in the area which in term will assist the Council in meeting its other priorities.

Principle 5: Planning for urban and rural areas:

Whilst ‘Optimising the quality, density and range of uses being developed in urban areas and on Brownfield sites’ is in general a sound principle it is not clear what this will mean in practice and how it will affect other principles such as meeting housing and employment needs. This will no doubt be a matter for future stages of the Local Plan review. However, as evidence of the availability of Brownfield land already exists it would have been useful to understand what capacity for growth exists in the urban area. This could have been expressed as a minimum and maximum.

The fourth bullet of Principle 5 states ‘If the Bristol and Bath Green Belt is reviewed, and parts of it are required to meet growth needs, ensure its long-term purpose and function is maintained and its recreational value enhanced.’ It is noted that other than building block 1 all options would potentially require Green Belt review.

Principle 6: Provide the right type and number of new homes:

Bullet point 1: Allocate sites to deliver new homes to meet the need identified in the West of England Spatial Development Strategy is supported but should be amended to reflect the requirement to provide for objectively assessed needs whilst significantly boosting the supply of houses. It is very unlikely that Bristol will be able to meet its full housing requirement and as a result adjoining Authorities such as South Gloucestershire will need to accommodate unmet need as part of the Duty to Co-operate.

Bullet point 2 of Principle 6 states ‘Provide homes that meet the needs of all our communities including Affordable Homes.’ As set out earlier in these representations it is disappointing that the Council has not included some evidence of likely need in South Gloucestershire in the evidence base.

It is agreed that ‘a portfolio of sites, of different sizes, in a range of sustainable locations across South Gloucestershire.’ (Bullet Point 3) should be provided as this will help to maintain a sufficient and flexible supply of housing. This will be critical to meet the subsequent stated principle of ‘Provide resilience to our 5-Year supply of housing land’ (Bullet point 4).

The principle of Exploring ‘new forms of landownership and delivery models, to deliver a range of housing types’ (Bullet point 5) is supported.

The West of England Housing Delivery Strategy (reported to the West of England Joint Committee on 29th January) notes that ‘In the West of England, LiveWest, Sovereign, Curo and Bromford’ have strategic partnerships in place and between them have committed in principle to invest circa £315M in the WofE and to establish a long-term relationship as investment partners.’ This type of approach will help achieve the Housing Delivery Strategy stated aim ‘to increase and accelerate housing delivery of all tenures and the interventions that can be made at strategic, regional level to maximise the impact of collaborative effort.’

Principle 7: Enable a productive, clean and inclusive economy:

In relation to Bullet point 4 it is important that the Local Plan review seeks to address the objectively assessed need for employment land and jobs rather than the potential less positive requirement identified by the West of England Spatial Development Strategy.

Principle 8: Achieving sustainable travel and transport:

The aim of ‘Achieving sustainable travel and transport’ is supported as is ensuring that ‘New growth should be in close proximity to existing or new key services and facilities, to create walkable and cycleable neighbourhoods.’

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

It is agreed that ‘New development through its location, design and contribution should support the long-term success and sustainability of Schools, community infrastructure and open spaces’ and that a ‘range of landownership and delivery models’ should be considered. Strategic development sites will need to play a key role in ensuring that community infrastructure, such as Schools, are delivered in a timely manner to avoid a strain on existing facilities.

6: Strategy- Where will development go

Do you agree with the five building blocks (Urban Areas, Urban Extensions, Market Towns, Rural Villages, New Settlements)?

  • Yes
  • No
  • Don't Know

7: Strategy- Where will development go

Do you have any comments on the five building blocks (Urban Areas, Urban Extensions, Market Towns, Rural Villages, New Settlements)?

In general terms the five suggested building blocks appear reasonable. However, it would be helpful to know if any options have already been discounted by the Council.

According to the Consultation Document, the Council is clear in its position that the likelihood of meeting all of its needs for new homes and jobs in the urban areas, with Building Block 1, are low. Page 63 of the Document identifies that greenfield extensions to urban areas, towns and villages may offer the next best opportunity in meeting the needs of the District.

Whilst the total number of new homes that the Plan will need to provide will be set out in the SDS, South Gloucestershire will likely need to accommodate the cross boundary needs of Bristol under the Duty to Co-operate, as well as its own. Under the Government's current standard methodology, Bristol City Council will be expected to deliver at least 3,196 new homes per annum and it is widely suspected that the City will not have the capacity to meet this.

For South Gloucestershire specifically, the Consultation Document identifies a requirement for at least 1,412 new homes per annum, equivalent to 21,180 new homes over the proposed Plan period (2023 – 2038). The Council’s 2019/20 Housing Trajectory suggests that approximately 8,931 units could be completed from 2023 onwards and so, on that basis, the Council would need to find land for 12,249 new homes over the proposed Plan period, in addition to the sub-regional needs of Bristol and BANES.

According to the Council’s proposed approach, Building Block 2 would witness the expansion of the main urban areas along the Eastern and Northern Fringes of Bristol through small or large urban extensions. This, we believe, would be the most sustainable approach for meeting the housing numbers which are to be established through the SDS.

The Council’s Phase 1 Sustainability Appraisal (SA) identifies that urban extensions to the fringes of Bristol (Building Block 2) could result in significant positive effects in relation to access to healthcare services, community facilities, education, retail, major employment areas and green infrastructure, as well as reducing levels of deprivation. Page 29 of the SA notes that the Local Plan presents further opportunities to allocate new housing development sites at locations which are in close proximity to existing healthcare facilities, open spaces and other facilities, which might encourage healthier lifestyle choices.

Sites on the Eastern Fringes – such as our client’s land at Longwell Green (see Site Location Plan at Appendix 1 to this Form) – are well-located for meeting the needs of the District and what is expected to be an ‘overspill’ of housing need in Bristol. As we go on to explain in these representations, our client’s site is capable of delivering housing-led development that would achieve many of the positive effects outlined in the SA.

However, the Green Belt is a clear policy obstacle to achieving sustainable levels of growth across the District, in particular on the Eastern Fringes of Bristol. We note this given the disproportionately low number of non-Green Belt sites put forward as part of the 2020 Call for Sites. With this in mind and noting the Council’s acknowledgement that it will need to consider greenfield extensions to main urban areas, it must undertake a detailed Green Belt Review at the earliest possible opportunity.

Under Building Block 3, the potential for sustainable growth would be investigated around the edges of the three market towns of Yate, Chipping Sodbury and Thornbury. Whilst we do not specifically object to this approach, we would highlight the extensive levels of completed and committed housing growth that has occurred in these towns already during the course of the current Plan period (2006 – 2027).

Taking Thornbury as an example, Policy CS15 of the Core Strategy identifies that 800 new homes should be developed in the town during the Plan period (up to 2027). Data from the Council’s AMR’s (2013 – 2019) suggest that during the first six-year period that the Plan was adopted, 749 new houses were completed, equivalent to 93% of the town’s indicative phasing capacity over the 15 year period. As of August 2020, the Council’s Data & Access Profile (November 2020) confirmed that Permissions exist for a further 701 new homes in the town. With 7 years of the current Plan period left some, if not most, of these consented homes could be delivered, taking the total number of housing completions in the town to nearly double that was planned for.

Similar conclusions may be drawn in relation to the market towns of Yate and Chipping Sodbury which, akin to Thornbury, are reported by the Council to have higher levels of commuting (Page 108 of the Consultation Document).

Therefore, in investigating the potential for sustainable growth around the edges of the three market towns, consideration must be given to the extensive level of completed and committed housing growth already. These towns are essentially ‘overheating’ and strategic levels of growth in these locations would be neither socially or environmentally sustainable, and would only serve to increase levels of commuting to key employment areas in and around Bristol.

Building Block 4 would result in the potential for an appropriate level of sustainable growth in and around the wide range of rural villages and settlements in the District. Under the Building Block which is considered further at Chapter 7 of the Consultation Document, Longwell Green is identified as a “rural village and settlement,” despite it evidently forming part of the existing urban area on the Eastern Fringe of Bristol, in proximity to Hanham Town Centre. We therefore object to Longwell Green’s classification as a “rural village and settlement.”

Building Block 4 should result in the consideration of appropriate small-scale growth in and around villages such as Cold Ashton, Marshfield and the many truly rural settlements of the District. The status of such villages within the settlement hierarchy is much lower and, given their much lower accessibility credentials than other more sustainable locations (Building Blocks 1 and 2 in particular) and the constraints that many of these areas face (such as lack of infrastructure), only small-scale growth opportunities should really be considered.

8: Strategy- Where will development go

Do you agree with the initial guiding principles?

  • Yes
  • No
  • Don't Know

9: Strategy- Where will development go

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

In general guiding principles are helpful to establish where development should go. However, it is inevitable that development on greenfield land will be required and as a result some variation to the stated six principles should be applied. Once the objectively assessed need for the area and any unmet need is confirmed development should be located in the most sustainable locations where key services and facilities are easily accessed by walking and cycling or effective Public Transport. Areas at the highest risk of flooding should be avoided along with environmental assets of most importance such as the AONB and SPA, SAC, Ramsar sites etc. Land currently designated as Green Belt should not automatically be discounted from being considered under these principles. Whilst green infrastructure and sense of place are important considerations these are more detailed design considerations which should not influence the locational strategy of the Plan.

The guiding principles would be better expressed (in priority order) as follows:

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;

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

3) Protect and enhance the most important ecological, landscape and heritage designations and their settings.

In addressing the above principles consideration will also be given to the following:

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

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

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

10: Urban Lifestyles

Do you agree with our Urban Lifestyles approach to investigate further change and growth in our urban areas?

  • Yes
  • No
  • Don't know

11: Urban Lifestyles

Do you have any comments on the Urban Lifestyle approach to investigate further growth and change in our urban areas?

The Council has acknowledged that the likelihood of meeting all of its needs for new homes and jobs in the urban areas are low. Greenfield extensions to urban areas can offer a sustainable solution for meeting the needs of the District, in particular on the Eastern Fringe of Bristol, and should be investigated further.

12: Urban Lifestyles

Do you agree with the areas where the Urban Lifestyles approach should be investigated?

  • Yes
  • No
  • Don't know

13: Urban Lifestyles

Do you have any comments on individual locations we have set out, or other locations which should be investigated for an urban lifestyles approach for further growth and change in our urban areas?

«No response»

14: Creating Sustainable Rural Villages and Settlements

Do you agree with our proposed approach to the national policy issues highlighted,  like flood risk, the Cotswolds Area of Outstanding Natural Beauty, Green Belt, and other planning considerations and issues?

  • Yes
  • No
  • Don't know

15: Creating Sustainable Rural Villages and Settlements

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

The Council is proposing to investigate appropriate levels of growth in areas where sites have been identified through previous Call for Sites, up to 200m from the edges of existing urban areas. Longwell Green is identified as one such place for investigation; though, as we have noted, it should not be regarded as a “rural village and settlement” under Building Block 4. Indeed, Longwell Green is included in the Urban Place Profiles forming part of the evidence base.

The Council’s proposed approach to investigating an appropriate level of growth involves the consideration of key sustainability issues such as; (a) proximity to key services and facilities and; (b) access to effective Public Transport connections, having regard to its Data & Access Profiles (November 2020). No comparison of each assessed location is provided though.

Whilst Longwell Green should not be considered as a “rural village and settlement,” it should be regarded as a highly accessible and sustainable location for greenfield urban extension. Our client controls a large parcel of land to the West of the urban area of Longwell Green (see Appendix 1). The land is not within an area of high flood risk, is relatively unconstrained by environmental designations and readily available for development.

The site is in close proximity to the centre of Longwell Green. As confirmed within the Council’s Data & Access Profile, a number of local facilities including; (a) three Pharmacies; (b) two convenience stores; (c) four supermarkets; (d) a Post Office; (e) a community centre and; (f) three Public Houses are located within a short walk of the site. Bristol City Centre and Bath City Centre is a 31 – 45 minute bus ride away from Longwell Green, with Keynsham being accessible by bus within 15 minutes. The site is also within cycling distance of a number of transport hubs including Keynsham train station, and its allocation for housing would provide a real opportunity to enhance the Public Transport network within its vicinity.

Having regard to the conclusions of previous technical analysis, summarised in our Promotional Document at Appendix 2 a high-quality sustainable development of around 500 dwellings could be provided on site. The development of the site could secure; (a) the delivery of and increased access to green infrastructure including public open space; (b) the delivery of high-quality housing and; (c) access for its residents to healthcare services, community facilities, education, retail and employment opportunities within and on the edge of Bristol; (d) new community or education facilities.

16: Creating Sustainable Rural Villages and Settlements

Are there any other planning issues you think we should consider?

Page 63 of the Consultation Document confirms that the prospect of the District meeting its housing needs, including an expected ‘overspill’ from Bristol, within the existing urban area is low. Sustainable sites which are up to 200m from the edges of existing urban areas must therefore be considered for housing.

However, many of these sustainable sites on the edges of the existing urban areas, including our client’s site at Longwell Green, fall within the Green Belt. In our opinion, the development of such sites is the most sustainable and logical approach for delivering housing within the District, therefore, it should be incumbent upon the Council to conduct a detailed review of the Green Belt.

17: Policies

Do you agree with the range and scope of policies we are proposing to include in our new Local Plan?

  • Yes
  • No
  • Don't Know

18: Policies

Do you have any comments on the range and scope of policies we are proposing?

The purpose of the consultation is to discuss the issues, priorities and potential approaches that the new Local Plan might take to manage change and growth within South Gloucestershire. This is confirmed on page 10 of the Consultation Document.

The list of potential policies on pages 143 – 151 should therefore be regarded as premature, since the issues, priorities and potential approach for the Plan have not been properly considered, let alone decided upon. It is simply too early to decide on the range and scope of policies at this stage.

The consideration of any policies should be carried out at the Phase 2 consultation stage in the Plan-making process when the overall strategy for the District will be considered, having regard to the requirements of the SDS. This will enable a more rounded assessment of any draft policies, noting the identified issues and priorities for the District and the approach for the Plan.

19: Appendix 2: Draft policies: Climate Change and Mitigation

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

20: Appendix 2: Draft policies: Climate Change and Mitigation

Do you think there are any other issues we should consider in this policy?

«No response»

21: Appendix 2: Draft policies: Energy Management in New Development

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

22: Appendix 2: Draft policies: Energy Management in New Development

Do you think there are any other issues we should consider in this policy?

The Government consulted on plans for the Future Homes Standard, including proposed options to increase the energy efficiency requirements for new homes in 2020. The Future Homes Standard, which is to be introduced by 2025, will require new build homes to be future-proofed with low Carbon heating and world-leading levels of energy efficiency. The Government proposes that Building Regulations Standards will be uplifted as a steppingstone towards the Future Homes Standard, and in particular towards future-proof homes with low Carbon heating.

Responding to the consultation on the Future Homes Standard, the Government recently (19th January 2021) set out plans to improve the energy performance of new homes, with all homes to be highly energy efficient, with low Carbon heating and be zero Carbon ready by 2025. These homes are expected to produce 75 - 80% lower Carbon emissions compared to current levels. To ensure the development industry is ready to meet the new standards by 2025, new homes will be expected to produce 31% lower Carbon emissions from 2021.

In light of the recent Government announcement, made subsequent to the publication of the Consultation Document, the identified policy options for net zero Carbon is considered to be broadly compliant with the Future Homes Standard. The precise policy wording should be considered at the Phase 2 stage of the Plan-making process.

23: Appendix 2: Draft policies: Renewable and Low Carbon Energy System

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

24: Appendix 2: Draft policies: Renewable and Low Carbon Energy System

Do you think there are any other issues we should consider in this policy?

«No response»

25: Appendix 2: Draft policies: Creating well-designed places

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

26: Appendix 2: Draft policies: Creating well-designed places

Do you think there are any other issues we should consider in this policy?

The proposed policy wording is extremely lengthy and should be broken down into its constituent parts in relation to green infrastructure, public realm, sustainable construction, accessibility and design. The precise wording for the draft policy or policies will need to be considered at future stages of the Plan-making process.

27: Appendix 2: Draft policies: Parking Requirements

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

28: Appendix 2: Draft policies: Parking Requirements

Do you think there are any other issues we should consider in this policy?

The Government is proposing to alter the Building Regulations for new residential buildings to include a requirement for electric vehicle charging infrastructure. Pending the Government’s review of a consultation that it led for the proposed changes in 2019, and in response to the Climate Emergency, it is proposed by the Council to outline a policy requirement for at least one active charging space per dwelling, with the remainder comprising passive provision.

Not everyone has, or will have, access to an electric vehicle when the Local Plan is adopted. There is no universal charger type, and so any requirement for developers to provide active charging points could render their installation obsolete for certain vehicle models. Besides being highly inefficient, this would add significantly to development costs, potentially delaying the delivery of new housing and bringing into question the viability of housing schemes; in particular those on Brownfield or otherwise constrained sites.

With the above in mind, the proposed policy requirement for at least one active charging space per dwelling should be rejected. A much more sensible alternative would be a policy requirement for 100% passive charging infrastructure, since this would then enable homeowners to make them active to suit, when required.

29: Appendix 2: Draft policies: NSIPs and Related Development

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

30: Appendix 2: Draft policies: NSIPs and Related Development

Do you think there are any other issues we should consider in this policy?

«No response»

31: Appendix 2: Draft policies: Nuclear New Build

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

32: Appendix 2: Draft policies: Nuclear New Build

Do you think there are any other issues we should consider in this policy?

«No response»

33: Appendix 2: Draft policies: Oldbury A Station - Decommissioning

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

34: Appendix 2: Draft policies: Oldbury A Station - Decommissioning

Do you think there are any other issues we should consider in this policy?

«No response»

35: Appendix 2: Draft policies: Radioactive Waste

Do you agree with our proposed policy approach?

  • Yes
  • No
  • Don't Know

36: Appendix 2: Draft policies: Radioactive Waste

Do you think there are any other issues we should consider in this policy?

«No response»

Q37

Phase 1 General or Other Comments

The Context to this Local Plan review is an important issue and should be highlighted. Paragraph 10.10 of the Adopted Core Strategy (2013) confirmed that ‘To ensure sufficient land is made available to meet housing needs to the end of the Plan period the Council will undertake a review of the Core Strategy/Local Plan to be completed before the end of 2018.’

As the Joint Spatial Plan (JSP) has been withdrawn, the earlier Local Plan review in 2018 did not progress. Consultation on the new SDS has yet to commence and as such there is a pressing need to adopt a new Local Plan as soon as possible. Without this in place speculative development in less sustainable locations could occur and delays in the delivery of jobs and houses will continue to exacerbate the affordability gap.

The development industry was generally supportive of the JSP as a mechanism for guiding new development, allowing Local Plan reviews across the West of England to be completed and providing certainty. Unfortunately, the approach taken in preparing the Plan was flawed with a general feeling that the evidence base had not been properly taken into account. Moving forward it is critical that lessons are learned so that the overall strategy for the area can be supported by stakeholders and rapid progress can be made in relation to a new policy framework for the area.

With such a wide range of stated issues there will inevitably be conflict. Therefore, the Council will need to very clearly communicate how the identification of issues has led to the stated Plan priorities.

Whilst the Local Plan Phase 1 Consultation Document considers a wide range of topics it does not consider these in combination by bringing them together in a single strategy. In accordance with the NPPF the presumption in favour of sustainable development should be a fundamental aspect of the Plan's focus. This will ensure that new development is located in the most sustainable places, in close proximity to complementary uses (i.e. houses close to jobs, shops and community infrastructure) with the least environmental impact. Whilst Climate Change and other environmental concerns are significant issues to consider the Plan should identify and provide for objectively assessed needs (NPPG Paragraph: 036 Reference ID: 61-036-20190723).

Linked to the ‘presumption’ the inter relationship between South Gloucestershire and Bristol should also be included as a fundamental issue. The concentration of jobs, facilities and services in Bristol cannot be overlooked. Locating development as close as possible to Bristol is likely to result in the most sustainable form of development, subject to relevant environmental constraints and designations.

Q38

Consultation ‘Other’ comments (Call for Sites, WECA and SDS, Evidence base, other strategies, planning applications)

«No response»