South Gloucestershire New Local Plan Phase 1 Responses

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Response #977544

Response #977544
From Robert Hitchins Ltd
Agent Barton Willmore
Date Started: 01 Jun 2021 12:52. Last modified: 15 Jun 2021 10:12
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.

We broadly support the Council’s identification of the respective issues subject to addressing the comments as set out below.

Furthermore, for the New Local Plan to be ‘sound’ the Council will need to ensure the Plan is positively prepared (in line with Paragraph 16 of the NPPF) by establishing a strategy which not simply meets the needs of South Gloucestershire’s administrative area but can also accommodate proportionate levels of unmet need arising from Bristol in sustainable locations. On that note we recognise that the consultation document does not make reference to the fact that Bristol’s standard methodology figure equates to 3,196 homes per annum, which represents a 142% increase of Bristol City Council’s current Local Plan requirement. Given the city’s spatial constraints it is unfeasible to think that this level of growth will be accommodated within the administrative area of Bristol and subsequently it is inevitable that South Gloucestershire will be required to take up an appropriate proportion of this unmet need. As a result of the above, we do not believe that the consultation document goes far enough in acknowledging the role South Gloucestershire will need to play in accommodating Bristol’s unmet needs. As part of any Spatial Strategy, we would continue to stress the importance of not only prioritising future development within existing urban areas, but the vital role sustainable rural villages can provide in contributing towards a sustainable pattern of development.

The Council highlights the necessity to undertake a “regional Employment Land and Spatial Needs Assessment (ELSNA)” together with an “Employment Land Review” to establish the quality and quantity of existing and future employment land throughout the Authority’s administrative area. Whilst we support this pragmatic approach, to ensure the soundness for the New Local Plan it is imperative that this work is carried out in accordance with the guidance as defined within the National Planning Policy Framework (NPPF). We would similarly continue to emphasise our support and encouragement for the Council to progress such work as soon as possible in order to establish a robust evidence base early on during the Plan making process. The merits associated with which will enable any future strategy to be underpinned by a reputable source of information to deliver the economic ambitions of the West of England whilst also capitalising on significant opportunities for future growth in key strategic locations including the Avonmouth & Servernside Enterprise Area (ASEA) and proposed Great Western Freeport area.

In light of the above, whilst we recognise the Council’s priority to protect and optimise employment provision on existing sites it is important for the local economy that new employment land is identified, allocated and subsequently comes forward over the proposed Plan period. Understandably the sustainability criteria of respective sites will be tested at a future stage however it will be important that the sites complement existing strategic employment provision (such as the ASEA) and are well-served by supporting infrastructure including direct connections on to the strategic highway and national rail networks.

Whilst the Council correctly focus on the need to make efficient use of previously developed land, this should not be at the expense of deliverability or creating unsustainable patterns of development and nor should it potentially result in restraining the economy through the loss of employment land within existing urban areas. Consequently, we would suggest greater emphasis needs to be attached to avoiding the potential loss of employment land within the defined urban area and the unintended consequences associated with urban intensification.

The accompanying Sustainability Appraisal states that within the context of South Gloucestershire a key consideration remains there is a “Lack of suitable land remaining within existing settlement limits for development which causes additional growth pressures in urban areas. This needs to be balanced with achieving a high quality of life and safeguarding our built and natural assets in urban locations” (Page 31). Consequently, we would suggest there would be significant benefits of undertaking an ‘urban capacity’ exercise to initially establish the scale of change anticipated within existing urban areas. Furthermore, this would enable the Authority to provide greater certainty on the quantum of new development envisaged over the Plan period whilst simultaneously allowing a more informed opinion to be made regarding the overarching balance between Brownfield, greenfield and Green Belt land. To achieve a sustainable pattern of development we believe that the New Local Plan should include a range of different sites across the Authority as part of the proposed strategy with a more diverse portfolio of sites to contribute towards a more resilient 5-Year Housing Land Supply.

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.

Whilst we support the Council’s approach to optimising future development on Brownfield sites in line with pursuing an ‘Urban Lifestyles’ approach. In accordance with Paragraph 118 of the NPPF for the New Local Plan to be sound the Council’s ambition to prioritise growth in urban areas should form part of a strategy which is supplemented by the inclusion of greenfield sites which are otherwise sustainably located adjacent to existing settlements, strategic employment facilities and established transport infrastructure. The inclusion of such sites would effectively integrate new development at sustainable locations throughout the region whilst also helping to ensure the Council do not pursue an approach which is potentially over-reliant on the delivery of Brownfield sites given their associated complexities.

In addition to the above, we would also note that there could be merit in establishing clearer connections between the importance of looking at the location of new homes and new jobs within the Plan area. In this regard, Pilning is well-placed close to the Avonmouth and Severnside Enterprise Area (ASEA), which is recognised as a regionally important employment facility and as part of the recent Great Western Freeport bid (as submitted by WECA) is projected to facilitate significant economic growth throughout the region.

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.

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.

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.

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?

«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)

SG481 - Land at Pilning.