South Gloucestershire New Local Plan Phase 1 Responses

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Response #916835

Response #916835
From Amanda Grundy - Natural England
Date Started: 30 Mar 2021 15:52. Last modified: 21 May 2021 13:12
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.

Statutory Body (Environment Agency, Highways Agency, Heritage England, Natural England etc)
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.

Issues:

In our view the document has identified and described the main issues facing the District and opportunities for the new Local Plan to ensure that housing, employment, renewable energy and other built infrastructure requirements are met in a way that minimises impacts on the natural and built environment and makes a positive contribution to the wellbeing of people and nature recovery and results in net gain for Biodiversity.

As noted in the document (page 28) the environment performs a range of essential functions for people and society but is under increasing strain from a variety of pressures. We therefore welcome and strongly support the reference to the “need to establish a mechanism to enable investment in the recovery of our natural resources to flow from the development that is sustained by it.” We think this should be a priority and that it will need to be co-ordinated with neighbouring Authorities and aligned with green infrastructure and nature recovery priorities.

We welcome the reference to the WoE GI strategy and to the WENP nature recovery networks mapping, which should help to inform the emerging South Gloucestershire GI strategy to direct action and investment most effectively so as to protect, enhance, restore and connect habitats and green infrastructure.

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?

Priorities:

The proposed priorities appear reasonable, including the urgent need to mitigate and adapt to Climate Change, to protect the natural environment and to ensure high quality multifunctional green infrastructure is planned and provided to secure the greatest social, economic and environmental benefits.

Inevitably there are potential conflicts between priorities, for example to protect and enhance the built and natural environment and to meet housing and societal development needs, although this will depend to some degree on the location, scale, type and design of new development.

Natural England regards green infrastructure as being essential to achieving sustainable development, as such we recommend that it is listed alongside other types of supporting infrastructure like transport, power, water and sewage, as these matters should all be considered and properly planned from the outset. We would encourage the Council to recognise green infrastructure as being a requirement for growing communities, alongside other infrastructure in priority 9. Ensuring the timely and efficient provision of infrastructure to support growing communities – indeed the early phasing of green and other supporting infrastructure will be essential to avoid creating isolated and otherwise unsustainable developments.

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)?

«No response»

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?

Building blocks:

The ‘building blocks’ focus on Brownfield land and increased density in urban areas, but also potential urban extensions at North and East Bristol Fringe, Thornbury and Yate and a new settlement somewhere in the District. Some more limited growth in other smaller and more rural settlements is also likely to be needed.

Two options relating to Green Belt are presented – Option 1 to only look outside GB for development sites and Option 2 to look across the District. The Sustainability Appraisal findings are clear that Option 2 is more sustainable in many ways, partly because the Green Belt is close to Bristol where most services and transport links are. Including GB in the search area would also provide more choice of potential development sites, which should help to meet most development needs outside the Cotswold AONB and with less impact on designated sites and important habitats.

However, until the location, scale, and type of proposed development is known, there is clearly potential for all options to result in a variety of direct and indirect impacts on the interests of designated sites, species and the Cotswolds AONB.

We also note that the Council has jointly commissioned a renewable energy stud, which will help to inform what type of technology should be used and where it should be located. Again, there are many potential landscape and ecological issues that could result from renewable energy development which will depend on its scale, location and design.

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?

«No response»

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?

«No response»

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?

New strategic and non-strategic policies:

The list of potential policies does not include a policy relating to Biodiversity net gain. We understand the Council is considering how BNG will be addressed in the Local Plan in the context of the 25 Year Environment Plan and forthcoming Environment Bill. We would welcome further discussion on this matter in due course.

We would expect further development of the strategic policy for ‘infrastructure and contributions’ to take account of comments above on recognising GI as part of essential infrastructure requirements and on the likely need for funding to support mitigation measures for managing effects on designated sites.

In terms of policy development, it will be important to consider the value of GI as an integrating approach as well as a tangible ‘outcome.’ This could mean that a policy for GI explains how it is delivered through other policies.

The Council is also consulting on some new strategic and non-strategic policies, including for Climate Change mitigation and adaptation; Energy Management in new development; Renewable and low Carbon Energy System; Creating well-designed places; NSIPs and related development; Nuclear New Build; and Oldbury A Station - Decommissioning. These all appear reasonable.

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?

With respect to the decommissioning of Magnox nuclear station, we are pleased that the proposed policy recognises the ecological and landscape sensitivity of its location and the need for a collaborative approach and master planning to minimise impacts and secure wider benefits for people and wildlife. We particularly note the intention to reinstate the habitat value of lagoon 3 for bird species associated with the Severn Estuary SSSI, SPA and Ramsar site. Natural England is supportive of this approach in principle and would welcome further discussion with the Council and other parties to explore this further.

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)

«No response»

Q39

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