South Gloucestershire New Local Plan Phase 1 Responses

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Response #932208

Response #932208
From James Durant - Cotswold Homes
Date Started: 19 Apr 2021 17:33. Last modified: 19 Apr 2021 17:33
Status Complete
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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.

Cotswold Homes commend the Council and fully support the thorough assessment of the issues that face the region over the proposed Plan period which are set out in the consultation document.

Issues 17 to 21 relating to the need for high quality, well designed places is something which is a fundamental driver behind all Cotswold Homes developments and is therefore fully supported by the company. Cotswold Homes have demonstrated exceptional design quality not only in the buildings delivered in recent years, but also in the places which have been created as part of those wider developments. Amongst others, such examples can be seen at Tytherington, Chipping Sodbury and Mangotsfield.

Cotswold Homes also fully support the drive to increase development in urban areas under Issue 22, utilising Brownfield and optimising densities through regeneration. In recent years Cotswold Homes have for example redeveloped the redundant School site in Mangotsfield, bringing much needed housing to the area, close to sustainable services and facilities. We would however offer caution as to over reliance on this as a tool for meeting the overall housing needs across the Plan period. Whilst it is recognised that it is sensible in principle to increase densities on Brownfield sites in the urban area, exorbitantly high densities are not always realistic in every context as this often requires high rise buildings which can accommodate large numbers of flats and this can jar with the character of surrounding development such as in suburban locations. It is also evident that whilst high densities may help meet a target number of dwellings over the Plan period, it does not recognise the complex make up of the need identified and the increase in flatted development as a percentage of the overall housing land identified, ignores the acute need for conventional family housing which is required in South Gloucestershire. Cotswold Homes therefore fully support the approach in promoting the effective use of urban areas for housing but would urge caution in the numbers that the Council settles on in terms of what can be expected to be delivered through such development across the Plan period. An unrealistic expectation will lead to problems with housing land supply during the Plan period and a reliance on speculative, non Plan led development, to plug the gap.

Cotswold Homes are also fully supportive of the recognition under Issue 26 of the requirement for growth in rural villages and settlements. It is pleasing that the Council recognises that an over reliance on major allocations in previous Plans and an expectation that growth in rural settlements will be covered by windfalls and infilling has not been successful in terms of ensuring that development at the rural settlements has come forward in a well planned and balanced way. The lack of firm allocations or even housing numbers being given to individual settlements has meant that even infilling at these settlements has led to a great deal of uncertainty for SME developers such as ourselves and for the communities who live in the rural settlements. The allocation of housing sites or at the very least the provision of numbers to settlements will give certainty to developers and communities alike and will allow constructive conversations as to where that housing should be provided to best reflect the aspirations of those communities, rather than facing arguments and uncertainty as to whether housing should be located there at all. The housing requirement under the standard method (notwithstanding the potential uplift taking account of Bristol’s unmet needs) is challenging due to its scale and even with large scale extensions to existing settlements and/or new settlements, growth at the villages is highly likely to be required. It is also evident as this issue notes, that a certain scale of growth is required even at smaller settlements to support local services and facilities as well as affordability issues. The Inspector noted in the report on the adopted Core Strategy that, having not been reviewed in 20 years at that time, it would be wise for a settlement boundary review to be undertaken at the rural settlements in the new Local Plan review which had been anticipated to be in place by 2018. As noted under Issue 34, the Government have also put a greater emphasis on smaller allocations being identified and this is likely something which would be most appropriate at the smaller settlements as part of a wider review of settlement limits.

Cotswold Homes are pleased with the recognition under Issue 32, 33 and 34 that small sites can play in delivering a consistent supply of homes, especially where the large scale allocations stall. Cotswold Homes have demonstrated in recent years that we are exceptionally placed to aid in the housing supply position of the Council, delivering homes on sites within an average of 3 months of receiving a consent. The historic reluctance across Local Authority areas to allocate a larger number of smaller sites as part of their overall housing land supply has meant that we have had to take greater risks to achieve consents and build out these smaller schemes on speculative schemes; perversely however it is the smaller SME housebuilders such as ourselves who are more vulnerable to the risks associated with such an approach than the larger housebuilders would be but the SME housebuilders have had little option but to pursue such an approach. Cotswold Homes are keen to work with the Council to enable the allocation of a greater number of smaller sites in a sustainable way, both in the rural villages and at larger settlements. We would be pleased to see the Council fully support local SMEs such as ourselves through the allocation of more than just the 10% target of the overall housing target to be met on smaller sites set by the Government and would certainly also advocate moving away from a strategy which relies on windfalls, but instead looks to provide certainty through allocating the usual windfall allowance to specific smaller sites.

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?

Cotswold Homes are fully supportive of the priorities highlighted by the Council for the Plan period and are acutely aware that a number of the priorities are interlinked and fundamental to achieving Priority 4 in relation to creating exceptional places and spaces. Achieving Carbon neutrality and resilient future homes as specified under Priority 1 is of course highly dependent on the quality of the individual buildings proposed as part of any scheme, but it is pleasing to note that the Council recognise that the Carbon footprint of buildings means nothing without the greater context of the need for high quality places being created as part of the wider scheme as well as the careful consideration of the location of the site. A new Local Plan provides an opportunity for the Council to improve the poor sustainability which has arisen from the speculative, piecemeal development that has come forward over previous years, through a Plan led assessment and allocation of schemes which can deliver community benefits and infrastructure which is missing from areas which have seen large levels of speculative development.

For the reasons set under our answer to the above question relating to Issues, Cotswold Homes are also fully supportive of Priority 6 which seeks to provide the right type and number of new homes. We re-iterate the importance of the allocation of smaller sites rather than relying on windfalls and rather than relying simply on large scale allocations to deliver the housing targets. As recognised by the Council, smaller sites help with the 5 year supply of housing land and the overall delivery of housing; Cotswold Homes have a proven track record of quick delivery of the schemes we have brought forward and this is something we will continue to do over the Plan period. Whilst the Council have noted that growth is required at smaller villages to help ensure the vitality of local services and facilities, it should also be noted that the lack of growth at settlements exacerbates affordability issues at those settlements and does not allow for the existing or future affordable housing needs to be met.

For example, ONS data demonstrates that as of June 2020, the median house price paid in England was £246,000, in South Gloucestershire was £278,000 but in rural areas such as the Frampton Cotterell Ward (which includes settlements such as Frampton Cotterell, Rangeworthy, Tytherington, Latteridge, Iron Acton, Engine Common and Coalpit Heath), the median price paid was £390,000; 40% higher than the South Gloucestershire average.

The data also shows that whilst median house prices in South Gloucestershire have increased by 46%, in rural Wards such as Chipping Sodbury and Cotswold Edge (which includes rural settlements such as Wickwar, Acton Turville, Old Sodbury and Hawkesbury Upton), house prices have increased by 55%.

Couple this with the data from the Council’s housing register waiting list which shows that for example as of 1st April 2020 there were 16 households who were accepted as being in need of affordable housing and had specified a need for an affordable home in Wickwar, it is abundantly evident that without growth at the villages neither the affordability issues or the affordable housing needs are likely to be resolved and the social aspect of sustainability will not be achieved.

With a track record of delivering high quality, policy compliant schemes in a timely fashion in rural settlements, Cotswold Homes are ideally placed to help the Council achieve the rural dispersal part of the housing strategy and would urge the Council to give serious consideration to the allocation of our sites put forward as well as working with us on identifying locations for future growth for us to focus our activities on.

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)?

Cotswold Homes are fully supportive of the proposed building blocks and recognise that a combination of these building blocks will be required to create a Spatial Strategy which fully meets the housing needs of the region across the Plan period in the most sustainable way.

With regards to the building block referred to as Urban Areas, we are fully supportive of this approach within urban areas and would re-iterate our previous comments regarding our desire to secure future Brownfield redevelopment opportunities across the region having demonstrated an excellent track record for delivering high quality schemes on such sites in recent years across the wider South Western region, including our scheme on the former Mangotsfield Primary School in South Gloucestershire. We would however emphasise our earlier comments in relation to the number of homes that the Council seek to rely on being brought forward through this building block. An unrealistic expectation on the number of homes which could come forward on urban sites (for the reasons set out previously but not repeated here) will only result in issues regarding delivery and the reverting back to speculative delivery of housing across the Plan period to resolve under delivery from urban areas. The over reliance on the Urban Areas building block should not be used as a tool for avoiding and reducing the more difficult discussions and decisions regarding the locations of greenfield allocations.

It was evident that the West of England Joint Spatial Plan (JSP) was found to be critically flawed by the Inspectors examining it, in the main due to the fact that there was no underpinning Spatial Strategy with which sites were both selected and also assessed against one another in the context of.

Inspector Malcolm Rivett gave further comments on this at the Examination and having listened back to the recordings of the Examination, those comments from 9th July were as follows:

“Many Local Plans will say well our Spatial Strategy is to put 50% of the new housing growth at and around our main settlement, we’ll put 10% at each of the next four settlements in the sustainability hierarchy and we’ll put 10% around the rest of the area. And then when you come to consider individual sites for development, you go well here’s our main settlement, we need 50% here…. these are our candidate sites, there are three candidate sites which all are reasonable alternatives, we only actually need two of them so we’ve got to decide…. which two of those three are the best.... and at that point you might start saying, this one is close to the town centre, this one doesn’t have the transport infrastructure implications, this one would be slightly less impact on landscape and you do all those…. but what you’re not doing at that point is considering the 953 other sites for development in the rest of the District because they don’t meet that aim and that’s what we feel is missing here.”

In this context it is pleasing to read that the Council are putting a heavy emphasis on sustainability in the Issues and Approaches consultation document and considering the opportunities for focussing development on the basis of a Spatial Strategy which revolves around a sustainability hierarchy of settlements and locations. As a SME housebuilder Cotswold Homes are fully supportive of further small to medium scale development at the Rural Villages and have a proven track record of producing high quality schemes, quickly at such locations; this includes our recent schemes at Tytherington, Chipping Sodbury and Rangeworthy. We would be keen to work with the Council to deliver further sites and would politely ask for the sites we have put forward to be seriously considered. We would also be keen to engage positively about potential locations for future growth through which we can focus our attentions when looking for new opportunities.

As alluded to in an earlier question response, whilst SME housebuilders are more vulnerable to the risks associated with speculative development, historically it has been the approach of many Local Authorities to only or predominantly only allocate development on the large scale sites which SME housebuilders are not part of due to the lack of the ability to compete with the PLC housebuilders in terms of securing those sites but also not able to deliver on their own due to the resources available to us in delivery of such infrastructure hungry sites. We would therefore urge the Council to support local SME housebuilders such as Cotswold Homes by giving us the certainty of allocations on sites. In this context we of course fully support the rural villages building block and would ask that the Council moves away from relying on windfalls which offer no certainty and instead seek to allocate sites and or specify a number of homes which should be delivered at the rural villages.

The Market Towns are of course some of the most sustainable locations outside of the identified Urban Areas of the previous Plan. As set out in our recent Call for Sites submission and as we have sought to demonstrate through the covering letter submitted with this questionnaire, Cotswold Homes have large land interests on the edge of Thornbury. As demonstrated in the Data and Access Profiles published as part of the evidence base to this consultation, Thornbury is a highly sustainable location and is able to be expanded without encroaching on Green Belt land.

Whilst in principle terms New Settlements can be a useful tool in certain circumstances to sustainably meet housing targets, we do not consider that the Buckover Garden Village proposals which formed part of the JSP accords with the general issues and priorities highlighted in the consultation document. Due to the speculative nature that Thornbury has grown over recent years, as recognised by the consultation document this has led to a lack of infrastructure being delivered alongside the housing due to the lack of a joined up Plan led strategy which would have been able to identify and deliver the infrastructure and funding for it. Focussing new housing at Thornbury now in a Plan led way can ensure that the North East of the town is made more sustainable through the provision of infrastructure (local centre, community buildings, play areas etc) where such infrastructure is currently lacking. Focussing development at Thornbury itself rather than a divorced extension at Buckover will also help to ensure that existing facilities and services remain viable through sustained populations and also can help to make new or improved Public Transport options viable.

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?

«No response»

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?

Fully supportive though see previous comments regarding over reliance on the delivery from such an approach.

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?

Cotswold Homes are fully supportive of the approach to create sustainable rural villages and settlements. As set out previously, the lack of identified growth at these locations in previous Plans has led to an acute affordability issue and damage to the viability of both local facilities as well as transport links. Due to this, a number of services and facilities such as convenience stores have closed due to the lack of an engaged local population to ensure their viability. The Council are right to now look at ways that delivery of development at these locations can help to actually improve their sustainability. As set out in the response to previous questions however, it is imperative that SME housebuilders who are likely to deliver such schemes are fully supported through being given the certainty that the principle of development is accepted through allocations. At the very least the Council should be seeking to proportion numbers to the rural villages and settlements on the basis of a considered sustainability hierarchy which can now easily be garnered from the thorough work done in the form of the Data and Access Profiles for each settlement. Cotswold Homes have a number of land interests at the smaller settlements which we have promoted through your Call for Sites and which are also considered more fully in our covering letter. These sites have the ability to meet local need in a sustainable way. Cotswold Homes also have a track record of delivering high quality design in a timely manner which will be crucial to the Council in keeping both high quality design at the heart of the Plan whilst also delivering the number of homes required at the pace anticipated. Whilst we understand and to a degree support the principle of considering small scale Green Belt release at the smaller settlements which are surrounded by Green Belt, the case for exceptional circumstances is likely to be very difficult to defend at Examination without a very robust strategy and evidence base. We would therefore advocate that the Council seeks to explore the opportunity to locate as much growth as possible within sustainable limits at the smaller settlements outside of the Green Belt before turning to consider Green Belt release at the smaller villages.

16: Creating Sustainable Rural Villages and Settlements

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

The Council should consider holding meaningful discussions with the bus operators to understand what level of growth may be required at various settlements to provide much more regular services at those settlements whilst it still being a viable commercial enterprise. Whilst small growth may be more suitable in terms of the existing scale of a village, larger scale growth could in certain contexts make a settlement far more sustainable.

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?

«No response»

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?

«No response»

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?

«No response»

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?

«No response»

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

«No response»

Q38

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

- Land West of High Street, Wickwar.

- Land West of Wotton Road, Rangeworthy.

- Various Sites at Falfield:

A. Heneage Farm;

B. Land South of Moorslade Lane;

C. Land East of the A38, Parcel 1;

D. Land East of the A38, Parcel 2.

- Land at Engine Common, Yate.

- Land to the North East of Thornbury.

Q39

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