South Gloucestershire New Local Plan Phase 1 Responses

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Response #958560

Response #958560
From Top To Bottom Ltd and Hanham C…
Agent George Yates - Knight Frank LLP
Date Started: 11 May 2021 16:55. Last modified: 11 May 2021 16:59
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.

See attached representations.

The Local Plan has identified a broad range of issues relevant to South Gloucestershire under 9 key themes. Our client broadly supports the issues identified and believes that a full understanding of these as an interrelated set of material considerations should guide the Council’s Spatial Strategy and residential development site selection. Our key considerations on these issues are considered below.

Key issue no. 27 (identifying the number of homes to plan for) recognises the need to plan for a minimum number of homes, which will include considering any sub-regional needs that may be set out through the emerging Spatial Development Strategy (SDS) that is being prepared by the West of England Combined Authorities (WECA). In December 2020 the Government published the response to the consultation on the standard method for assessing Local Housing Need which includes a 35% uplift to the post-cap number that it generates for the largest cities, including Bristol. Planning Practice Guidance has been updated accordingly.

The changes to minimum local housing need in the West of England sub-region brought about by this are as follows:

Please see the attached document, titled Hanham - Local Plan Phase 1 Reps, for the information referenced above (which is contained in a table on Page 3).

In accordance with Paragraph 24 of the National Planning Policy Framework (NPPF) “Local Planning Authorities and County Councils (in two-tier areas) are under a Duty to Co-operate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.” For the Spatial Strategy to be found ‘sound’ at Local Plan Examination (in accordance with Paragraph 16 of the NPPF), the housing requirement across the South Gloucestershire area will need to wholly consider not only the direct needs of its Authority area itself but the needs of the whole region, particularly those of Bristol because of the uplift identified above. In progressing the Local Plan, all documentation regarding the Spatial Strategy and the housing requirement should make sufficient reference to the potential requirement of meeting these additional needs.

Key Issue no. 26 (growth in Rural Villages and settlements) identifies that the Core Strategy did not allocate any sites for planned growth at sustainable rural settlements. In the absence of a 5-year housing land supply, the Council recognises that this has put significant pressure on rural community’s character and appearance, and existing services and facilities. In rural settlements and villages, it will be important for new ‘planned’ development to be delivered to enable and support the services and facilities needed to within established communities (as set out in Issue 45).

South Gloucestershire has a historic undersupply of housing, leading to a lack of 5-year supply situation across the District (Issue no. 33). The aim of the new Local Plan should be to address this failure, and in doing so, identifying varying sizes of housing sites that can be delivered in the short, medium and long term over the Plan period. There is a high reliance within the Core Strategy on the delivery of sites of strategic scale (Issue no. 32). Whilst it is fitting that strategic development plays an important role in the Council’s development strategy, as history will show, any delay to the delivery of these sites will result in an under-supply of housing across the District.

Whilst our client support’s the overall ambition of the Local Plan of prioritising Brownfield land, it is a concern that placing so much reliance on the delivery of urban living (Issue no. 22) is contrary to the requirements of the NPPF to have sufficient flexibility to changing circumstances and plan positively. Sufficient land needs to
be identified through the Local Plan to provide the land for housing needed for the Council to maintain a 5-year supply of land for housing.

Our client supports the Council In identifying the need for community infrastructure (Issue no. 49) and sport and recreation (Issue no. 50) which are important to boost the overall health, well-being and sustainability of a variety of areas. It will be important to recognise the role that new development can play to enable and support the new community and recreational development across the District.

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?

See attached representations.

At this stage in the Local Plan process the broad priorities outlined identify the key areas where there is a requirement to focus policy and strategy implementation. Identifying such priorities is useful to ensure that future policies and strategies developed around these when formulating more detailed areas of the Local Plan document.

Priority 6 should be clear that the objective is to embrace growth and significantly boost housing supply, in accordance with NPPF paragraph 59. The objective of meeting identified needs should be expressed as a minimum and recognising the potential across the District to meet regional needs where necessary should also be identified as a priority. Furthermore, it should be a priority that the Local Plan ensures this housing supply is boosted and can begin delivering immediately, allocating available and achievable land whilst learning from the experience of the current Core Strategy, as discussed above and outlined in Issue no. 32.

It is acknowledged that priority 6 identifies the requirement to ‘provide a portfolio of sites, of different sizes, in a range of sustainable locations across South Gloucestershire’ (Page 57). It is supported that the Spatial Strategy is underpinned by focusing development at ‘accessible’ locations that are well related to existing urban areas, served by existing sustainable transport routes, or with the ‘potential’ to be sustainable as a result of the ‘type and form’ of development proposed. This should be achieved through a detailed review of the Green Belt and an assessment of the most sustainable rural settlements, which hold a number of the characteristics required to achieve sustainable development.

Such a review would lead to achieving more sustainable patterns of development across the District in accordance with the South Gloucestershire Council’s Climate Emergency declaration.

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)?

See attached representations.

As previously mentioned in this letter, our client is supportive of the urban living approach more generally and considers that efficient use should be made of all previously developed land in these areas (Building Block 1:Existing Urban Areas). The risks of over-allocating development on this type of land have been considered earlier in this letter, and thus, it has also been identified that a mix of green field sites should be selected as part of the Council’s spatial development strategy.

As such, the allocation of sustainable housing sites on the edge of urban settlements close to existing infrastructure is wholly supported (Building Block 2: expanding our main urban areas through small or large urban extensions). This would generally result in the loss of Green Belt land as most of the urban areas at the North and Eastern Fringes of Bristol within the South Gloucestershire boundary are tightly constrained by Green Belt policy. Issue no. 44 (Green Belt) identifies that over 40% of South Gloucestershire is currently covered by Green Belt protection. Many of the surrounding sustainable settlements, including those at the urban edges including such as Longwell Green are surrounded by Green Belt which limits the settlement’s planned growth. It is necessary for a robust Spatial Strategy and housing delivery efficiency to deliver housing at both urban and sustainable urban fringe/rural locations.

Rural Settlements have a key role to play in delivering a sustainable Spatial Strategy (Building Block 4: Rural Villages and settlements), they should be investigated for their potential to provide a mix of small, medium or large scale growth depending on the supporting infrastructure and wider settlement sustainability principles. Key Issue no. 26 acknowledges that the Core Strategy allowed for infilling within existing village boundaries but did not allocate any sites for planned growth in rural settlements, or any non-strategic growth in urban fringe settlements. As such, many of these locations have seen very limited housing growth in the period since 2006.

The first guiding principle relates to the location of new homes, jobs or settlements and sets out to consider the proximity of potential locations to key services, facilities and sustainable transport options. The Green Belt covers a significant proportion of the District, including many highly accessible locations and settlements as recognised in key Issue no. 24 (Green Belt). It is therefore a major policy barrier to the achievement of sustainable development and a Carbon neutral green recovery. It is imperative that a thorough and robust assessment of the Green Belt is undertaken to ensure this guiding principle is achieved and that this should include assessing for large, medium and small scale growth options across the District’s settlements.

The Local Plan 2020 is intended to accord with the emerging SDS that is being prepared by WECA, along with North Somerset which is understood to be co-operating. The Local Plan should therefore acknowledge cross-boundary issues in developing its Spatial Strategy in recognition of the fact that the City of Bristol is the economic driving force of the West of England. Bristol also has the highest indicative Local Housing Need in the sub-region and there is very high demand for housing within or near to the city. The most sustainable locations in South Gloucestershire are often urban fringe locations, or settlements that benefit from proximity and/or good transport links to the Bristol urban area.

In accordance with Paragraph 32 of the NPPF, this new Local Plan should deliver its Spatial Strategy in accordance with the most sustainable development locations identified in through the preparation of a Sustainability Appraisal. This will ensure that settlements are tested for their levels if economic, environmental and social sustainability and development is allocated in the right places.

Our client agrees that a mixture of the building blocks for a development strategy will likely be required. The sites identified at Hanham and Longwell will assist with this along with a number of identified issues and priorities for the Local Plan. It is also agrees that a review of the Green Belt is required. The retention of the Green Belt means that, apart from urban intensification, the focus of development is further away from the Bristol urban area, which would be a less effective way of meeting housing and affordable housing needs. Also, there is clear evidence of Green Belt’s protection’s adverse consequences at the expense of all other objectives and priorities, including environmental protection, Climate Change, delivering a sufficient supply of homes, among others.

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?

See attached 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?

See attached representations.

Overall, the proposed approach is supported at this stage as a positive and proactive method by which to realise the urban lifestyle approach in certain communities within South Gloucestershire. The approach is supported by the NPPF which is clear that policies should make optimal use of previously developed land, and where possible look to increase density around town centres and Public Transport hubs.

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?

See attached representations.

The Local Plan notes that Hanham town centre is well-placed to service the surrounding suburban areas. The High Street retains a mix of retailers, GP Surgery, Pharmacies and a community centre. It also benefits from a moderate level of transport links and facilities with connections to Bristol, Longwell Green and Keynsham.

Of the three sites being promoted by our clients, Site 1 (Hanham Community Centre) and Site 2 (Hanham Sports Ground) both lie within the Hanham urban area, although only Site 1 is currently within the ‘Urban Lifestyle Location.’ Sites 1 and 2 could deliver in excess of 100 dwellings, along with a new community centre and possible commercial space at the High Street. Whilst not in the Hanham Urban Lifestyle area, the Sports Ground will be relocated to Site 3 at Longwell Green, which has additional space for sports provision and additional housing. Site 3 is included within section 7 of the Local Plan as a potential rural settlement to investigate for growth and is immediately adjacent to the urban edge.

The development of these sites will provide a moderate and appropriate level of growth to this part of the East Fringe, in doing providing new housing which will support local services and facilities, along with an increased offer for sport and recreational facilities. As such, these sites should be included as key sites for change in the Local Plan as they are deliverable and also accord with the urban lifestyle principles and the opportunities set out for Hanham.

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?

See attached representations.

Allocating development within and adjacent to rural sustainable villages is crucial to efficient delivery of housing across the District and to ensuring that the sustainability and vitality of our rural communities are enhanced. In adopting a ‘planned growth’ approach, development can respond each rural settlement’s identified needs and ensure that the right support is provided to communities alongside the correct scale, form, mix and design of new development. The selection of such locations for development needs to be based on a thorough understanding of a broad range of material considerations. Many of those are identified in the Council’s issues and priorities document. These include heritage assets, including Conservation Areas, Listed Buildings and sites of archaeological value. There are also landscape features like valleys, hillsides and escarpments, all of which help to create valuable, historic landscapes and distinctive places.

It is considered that the first option to only investigate locations outside of GB would not be sound as it would require a number of less sustainable settlements outside of the Green Belt to deliver to deliver a substantial proportion of the housing requirement. Furthermore, it is highly likely that South Gloucestershire will be expected to assist meeting a proportion of unmet housing needs arising from Bristol City, and therefore it would not be sound or sustainable to simply deliver these in locations that are beyond the Green Belt and highly detached from the urban area. It is considered that unmet housing needs should be met at or close to where they arise, i.e. near to Bristol. This is supported by paragraph 138 of the NPPF is clear that the need to promote sustainable development should be taken into account when reviewing Green Belt boundaries.

A balancing exercise in understanding all of these issues, followed by an allocation of a mix of sites is the correct approach to determining the Spatial Strategy. Our client fully supports the review of settlements both within and outside of the Green Belt (Appendix 1: Option 2). The SA states in Paragraph 4.126 that:

“In preparing subsequent stages of the Local Plan, the Council should consider a Spatial Strategy that includes a combination of villages and settlements within and outside the Green Belt. Option 2 performs better than Option 1 in sustainability terms, given its potential to provide residents with access to a wider range of services and facilities within the existing urban area.”

16: Creating Sustainable Rural Villages and Settlements

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

«No response»

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?

See attached representations.

The development of new and ambitious policy measures must meet the objectives and deliver against the priorities as set out in the Local Plan 2020 Phase 1 Issues and Approaches document. The development of new policies needs to be robustly evidenced and the impacts on adoption needs to be fully understood whilst being forward-looking and ambitious. Any new policy measures need to be based upon a robust evidence base to be found ‘sound’ (according to Paragraph 31 of the NPPF). This should include an assessment of their impact upon viability; both on an individual site level and on a whole-Plan basis. As such, we reserve the right to comment further following a review of the policy supporting evidence base.

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)

Site 1: Hanham Community Centre, 124 High Street, Bristol, BS15 3EJ.

Site 2: Hanham Sports Ground, 77 Abbots Road, Bristol, BS15 3NP.

Site 3: Land North of Abbots Road, Longwell Green.