South Gloucestershire New Local Plan Phase 1 Responses

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Response #945394

Response #945394
From Redrow Homes (SW)
Agent Matthew Kendrick - Grass Roots…
Date Started: 29 Apr 2021 19:04. Last modified: 29 Apr 2021 19:35
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.

Business or Company
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.

Please see enclosed representations.

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?

Please see enclosed representations.

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)?

Please see enclosed representations.

3.3 As we have set out in previous reps to the JSP, and as part of our separate submissions to the SGLP Phase 1 document, we consider it essential for legibility that a weighting system be applied to the SA assessment to aide legibility for the general public. If this is done and accepting the SA conclusions in respect of the 5 ‘building blocks’ the most sustainable options for development include the reuse of underused land within existing urban areas, followed by urban extension to Bristol, as Figure 2 below illustrates:

Figure 2. Assessment of ‘Building Blocks’ SA work with weighted system applied.

Please see the attached document for Figure 2 (as referenced above).

3.8 So, while assessing the potential to maximise the use of existing urban areas this should be realistic in terms of how these competing priorities are balanced, to ensure yields from this supply source are realistic. This will then identify a robust residual need that must be delivered elsewhere within the Authority area, by adopting the alternative ‘building block’ approaches.

3.9 This residual housing need that cannot be accommodated within existing urban areas, which we believe the Council agrees with us will be a substantial amount, should then be distributed in accordance with the SA work on the Spatial Strategy, reacting to other policy and socio-economic factors. Based on the current, and previous JSP SA work, in our view this clearly places an emphasis on meeting Bristol’s needs as close to its urban edge as possible, or in locations where Public Transport links to the city are string, such as at Yate.

3.10 However, we also appreciate that there are a range of different types of settlements across South Gloucestershire, and therefore a vast array of issues to address which in our view could not be solved through the adoption of one specific ‘Building Block’ as a Spatial Strategy. It is our view that a blend of the Building Blocks should be put forward to address the different key priorities and issues raised within the consultation document, with a significant proportion of land being allocated on the edge of Bristol, followed by Market Towns such as Yate, with rural towns and villages receiving a proportion of development needed to address their individual concerns (for example, sustaining local facilities, bringing in investment via CIL to local Parish Councils to spend on local infrastructure projects, and addressing surplus capacity available in Primary Schools).

3.11 We do not agree with the principle of allocating a new freestanding settlement if this involves land at Buckover, or anywhere in the Northern periphery of South Gloucestershire, being pursued as a development option. We have set out on many occasions within our representations to the JSP why we do not agree with such an approach, but this primarily relates to the impact this will have on Carbon emissions and air quality as it will result in residents travelling South to work in Bristol; and the infrastructure funding gap that was identified within the evidence base to the JSP as a result of needing to significantly extend the MetroBus infrastructure to the North to make this proposal even remotely accessible to the wider area, and avoid such a development becoming a large scale dormitory settlement.

3.12 We therefore consider that a ‘blend’ of Building Blocks will be required to meet the needs of South Gloucestershire and unmet need from Bristol, with the focus first being existing urban areas to ensure the most is being made of existing Brownfield and other opportunities within existing communities; and then the majority of the residual housing provided in urban extensions, which given the availability of jobs should be located adjacent to the Northern Fringe of Bristol, then finally a smaller proportion of growth provided at Market Towns (particularly at Yate for the reasons we will go on to explain) and sustainable rural settlements to reinforce their roles and ensure their longer term viability.

6.3 Based on the emerging evidence, and that presented as part of the JSP, we consider that after the use of land within existing urban areas has been maximised to deliver housing and employment growth, significant greenfield land will be required to meet SGC, and the wider WoE areas, development needs. This should be primarily located in sustainable locations such as on the edge of Bristol, near to existing employment and service hubs, and where it can support the continued role and function of important settlements such as Yate, which provide excellent Public Transport links into Bristol and facilities of their own which makes it a suitable location to accommodate growth.

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?

Please see enclosed representations.

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?

Please see enclosed representations.

3.4 We acknowledge and support a further strategy that focuses on these two key options. However, it must be accepted that the more intensive use of existing land within existing Urban Areas can only go so far, and capacity constraints will mean that this source of supply will not be able to meet the overall housing needs that the WoE SDDS, and consequently the SGLP, will be required to accommodate.

3.5 The work previously undertaken by NASH Partnerships ‘Maximising the potential of Urban Living,’ whilst a good starting point, was only ever designed to be a high-level assessment of potential land available in support of the JSP. As the SGC Local Plan is now focusing on site-specific allocations, it is our view that this should be further developed to identify specific sites that are capable of redevelopment or existing committed sites where it is appropriate to increase densities.

3.6 Not all urban areas will be appropriate locations within which to elevate densities above the levels we have recently seen. The COVID-19 pandemic has highlighted the need to provide dwellings with both sufficient internal space within which to work from home, and also suitable outdoor space. It is striking how the rates of infection have been so high in densely populated areas and the trend towards a greater prevalence of viruses in society, linked to increasing rates of ineffectiveness in antibiotics and other treatment we rely on to combat these viruses, may continue and planning for more densely populated areas may not be the best response to this.

3.7 Separate to this there had already been a trend towards consumers demanding private garden space for their health and wellbeing. Specifically, Redrow have seen strong demand for their Heritage homes as a response to the recent lockdowns and their desire for more garden area and space for home working.

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?

Please see enclosed representations.

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?

Please see enclosed representations.

16: Creating Sustainable Rural Villages and Settlements

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

Please see enclosed representations.

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?

Please see enclosed representations.

5.1 We note the consideration of the new planning policies that the Local Plan 2020 may contained set out at pages 138 - 151 of the consultation document. We agree that there is an opportunity to reconsider the detailed planning policy framework for the SGC area to react to changing factors such as the Climate Change emergency and the need to support existing communities and businesses following the COVID-19 pandemic and its related recession.

5.2 We have examined the emerging proposed strategic and non-strategic policies and do not disagree with the general scope of policies that are being proposed. We have also seen and read the draft policies that the Phase 1 Plan provides, and have comments in relation to the following:

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?

Please see enclosed representations.

Climate Change Mitigation and Adaption:

5.3 This policy sets out SGC aims to become Carbon neutral by 2030. This is a challenging goal and we do not disagree that it should be an aim, however we do agree with the flexibility that the current wording provides at point 1: ‘or the latest target set out in the Climate Change strategy,’ because this will allow the 2030 aim to be kept under review and not tie the Council to a target that becomes unrealistic due to changing circumstances.

5.4 We would also suggest that the words ‘where practical’ be added to criterion no.2 of the policy wording. Because while we fully support the need to maximise renewable/low Carbon energy sources as part of new development, in some instances certain technologies will not be practical (i.e. ground heat pumps in areas of shallow bedrock, wind power on visually exposed sites etc). The updates to Part L/F of the Building Regulations should be used to inform the proposed Regulation 19 SGLP2020.

5.5 We also welcome the policies reference to one of the key ways the aims of this policy will be met, namely by locating development where the use of the private car can be minimised. This reinforces the need to allocate land at places such as Yate, and not rely on new freestanding communities such as Buckover which have the strong potential, to become dormitory towns with little alternatives to the private car available.

5.6 We fully support the policy aims to locate development outside of areas prone to flooding, enhance access to recreational space to promote health and wellbeing, enhance Biodiversity and seek to provide opportunities for local food production, such as allotments.

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?

Please see enclosed representations.

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?

Please see enclosed representations.

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?

Please see enclosed representations.

Creating Well Designed Places:

5.7 We support this emerging design policy but would ask that the Council ensure it references, and remains consistent with, the published and emerging Central Government design guidance, as set out in the National Design Guide.

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?

Please see enclosed representations.

Parking Requirements, including Electric Vehicles:

5.8 We agree with the thrust of this policy. It has to be accepted that at the current time car ownership is a key part of people's lives and moving away from this will take time, therefore we support the maintenance of the current minimum car parking standards that the policy sets out but are in full support of the requirement that sites in the existing urban areas need to submit an accessibility statement to consider whether these minimums can be reduced in certain areas where accessibility to everyday facilities is good, and Public Transport options are extensive.

5.9 We also support the continued deployment of electric vehicle charging points in new developments, which Redrow is now delivering as part of the NW Yate development. However, the proposed new building regulation Part S Electric Vehicle charging, will require the mandatory installation of an active (live upon occupation) 7.2kw vehicle charging point on every new dwelling. This requirement has yet to be introduced by the Government. The Building Regulations requirement will become mandatory and therefore there will be no requirement for an associated planning policy.

5.10 The upcoming requirement for electric vehicle charging per dwelling plus upcoming reliance on electricity to power low Carbon heating systems, will lead to increased demand from utility providers and the overall supply bank of electricity generally.

5.11 South Gloucestershire have not provided evidence from Western Power Distribution that there is sufficient capacity within the grid to support increased demand from these proposals or that they can adequately supply the new homes market in complying with these criteria. Any improvements to the electricity supply network to improve supply have not been identified.

5.12 Costs associated with improvements to electricity supply infrastructure across the whole Authority should not be borne by developers.

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?

N/A.

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?

N/A.

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?

Please see enclosed representations.

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?

N/A.

Q37

Phase 1 General or Other Comments

6.1 We are pleased to see the SGC Local Plan being progressed and it appears that the documents prepared have gone back to the beginning. We urge the Authority to not be tempted to fall back into making the same mistakes as that within the JSP and ensures that the evidence base underpins the most sustainable strategy and in particular meets Climate Change goals.

Q38

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

Land at North West Yate.

Q39