South Gloucestershire New Local Plan Phase 1 Responses

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Response #977497

Response #977497
From Robert Hitchins Ltd and Harrow…
Agent Barton Willmore
Date Started: 01 Jun 2021 12:24. Last modified: 15 Jun 2021 18:00
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.

Please see enclosed submission.

Whilst the Council has recognised a number of pertinent issues, we would continue to highlight the importance of any Spatial Strategy remaining flexible in order to accommodate suitable levels of future growth as expected to be set out through the West of England Combined Authority (WECA) Spatial Development Strategy (SDS). As part of the current planning system, and 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 prescribed bodies, on strategic matters that cross administrative boundaries.” Moreover, for the new Local Plan to be ‘sound’ South Gloucestershire Council will need to ensure the Plan is positively prepared by establishing a strategy which not only seeks to meet the objectively assessed needs of the region itself but can also accommodate an appropriate proportion of Bristol’s unmet need over the Plan period.

Issue 22 seeks to increase development in urban areas. Whilst the principle of optimising previously developed land is supported, the Council rightly recognises that the quantum of such sites may be constrained and as such it will be important for the Council to demonstrate the viability of those sites within the urban area that will be expected to come forward over the proposed Plan period.

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 submission.

In response to Priority 6 “provide the right type and number of new homes” we would add the following comments:

• The emerging Local Plan will indeed need to meet the development requirements of the SDS including housing needs that cannot be met in Bristol. For the overall soundness of the Plan, it will also be important that the Council consider exceptional circumstances for removing land from the Green Belt in order to accommodate sustainable development.

• It is right to identify that a “portfolio” of sites will be needed. This must not include an over reliance on Brownfield sites and should recognise the need to allocate suitable greenfield land. A Green Belt review will be needed to accommodate sustainable development.

• As part of any Green Belt review it will be important to recognise that Easter Compton offers the opportunity to accommodate sustainable development and that our clients’ land does not make a significant contribution to the purposes of that designation when compared to other alternatives.

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 submission.

We broadly support the five Building Blocks identified by South Gloucestershire Council which are helpful in illustrating the options available. In reality more than one option may well be needed to meet the development needs of South Gloucestershire. To ensure the soundness of the emerging Local Plan we would continue to emphasise the importance of providing a diverse portfolio of sites in a range of sustainable locations to accommodate growth across the region. The sustainability credentials of future sites will inevitably be subject to further consideration as the process continues, however proximity to the existing urban area of Bristol, connectivity to strategic employment provision and accessibility to transport infrastructure should form essential factors to achieve more sustainable patterns of development. We would anticipate the Spatial Strategy being informed by a combination of all respective Building Blocks.

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 submission.

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 submission.

We broadly support the principal of the Council’s Urban Lifestyles approach, but the new Local Plan will need to ensure it is not subject to an over-reliance on the delivery of Brownfield land. We would initially note the following:

• There is an insufficient supply of urban land and windfall sites available. In order to ensure the new Local Plan is able to meet identified housing provision requirements via the Council’s Urban Lifestyle approach, a robust supporting evidence base is necessary. This should reflect the strategic housing land availability assessment which provides specific details regarding deliverability, anticipated timescales and viability constraints;

• Any future strategy should have regard to the timescales associated with bringing forward Brownfield sites in order to identify a robust capacity for South Gloucestershire’s existing urban area and appreciation for historic delivery rates to ultimately establish realistic expectations regarding Brownfield regeneration.

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?

Please see enclosed submission.

1. The population of a settlement is worth looking at but only as a proxy for other indicators of sustainability such as the existing population;

2. The level of growth in recent years is not in itself considered to be a helpful indicator. The fact that there may not have been much growth in certain areas over recent years (as in the case of Easter Compton) means these locations may well now warrant the need for further new development;

3. The availability of infrastructure is important, and the Plan should look not just at capacity but also the benefits and practicalities of improving these networks (in the case of Easter Compton we would point to the potential for existing and improved Public Transport benefits);

4. Access to supporting services and facilities is very important and existing policy has helped in this respect, however it is also pertinent to look at proximity to higher order facilities and strategic employment provision in particular (the strategic advantages of Easter Compton are set out elsewhere in these representations);

5. It is relevant to consider the designations identified within the consultation document but only in a way that reflects the approach of the NPPF and having regard to the objective of contributing to the achievement of sustainable development (we have set out elsewhere in the approach necessary in respect of the Green Belt).

16: Creating Sustainable Rural Villages and Settlements

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

Please see enclosed submission.

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 submission.

Whilst supportive of the new Climate Change and energy measures proposed, we would advocate that a consistent approach is adopted nationally across the West of England to provide developers with greater certainty. Any new policy measures need to be based upon a proportionate evidence base which is deemed to be ‘sound’ and this should include an assessment of their impact upon viability; both on an individual site level and on a whole-Plan basis to ensure that other policy aspirations are not unduly impacted (e.g. affordable housing).

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)

SG280 - Land at Easter Compton.