Section 2 : Site Selection Process
Do you support the process, as set out in section 10 of the Topic Paper, used to select sites which are currently included in the Emerging Spatial Strategy?
The cobbling together of a selection of sites for housing, without consideration of travel links, job opportunities, retail and entertainment requirements, nor infrastructure, cannot be
regarded as a comprehensive "Plan".
The current "broad sweep" numbers (whether imposed by Central Government or generated by South Gloucestershire Council) are far too simplistic for the process of formulating a viable Local Plan.
If Local Authorities/Central Government are going to intervene into the housing market, these basic "housing requirement" numbers are just the start of the process. The "housing Market" is not limited to the provision of 3/4 bed speculative housing "units".
No statistical evidence of actual housing needs, has been evidenced within this “Strategy”
document.
Once a "target" total (of housing numbers) has been determined, the actual separate Housing need categories will require detailed analysis. The basic Categories of accommodation required for future households, across all age groups will each have specific space and locational requirements.
Homes for Social Rent - This accommodation, which is desperately required will need to be
located on regular transport routes, close to "High Street" facilities, recreational facilities,
doctors, schools, etc., etc. and will require direct intervention by South Gloucestershire Council, as this provision cannot be left to speculative property developers.
Similarly, provision needs to be made for active, self sufficient older home-owning residents.
Provision of these facilities would facilitate re-location from larger properties and "free-up"
family-sized accommodation for others.
Apartments can provide the accommodation for "entry level" access to Home Security and can be constructed to higher density, enabling more accommodation to be provided on smaller, semi-urban sites.
Other Local Authorities are providing "Solo Haus" accommodation on small areas of their estate, in sustainable locations, to provide accommodation for individual occupation, relieving pressures on the rental market — no details of SGC involvement in such schemes have been indicated here.
A number of the proposed sites are within the established Green Belt, which remains protected by the latest edition of The National Planning Framework - December 2023, which maintained the approach that only in "Exceptional Circumstances" could Greenbelt land be used for housing development.
However, sections 9.6 and 9.7 of the Consultation document are ambiguous and suggests that due to South Gloucestershire having a high proportion of Green Belt designated land, this wonderful asset should be "released" to meet the unsubstantiated housing "need," without any "exceptional circumstances" being stated.
How can this "Plan" be promulgated when it contravenes current legislation? Surely the "Plan" must reflect the current situation/restrictions, pertaining at date of publication.
Ambiguity continues through the document, with the HELLA assessment of the "favoured"sites — site referenced SG032, is a prime example, it remains on the schedule of developable sites, yet after considerable time and deliberation, this particular site has now been refused planning permission, not solely due to the fact that the site is designated Green Belt, but on a comprehensive list of other issues, examined in depth and firmly argued as grounds for refusal.
Surely, this demonstrates that the application of the HELLA assessment formula to the other
scheduled sites is insufficiently robust/reliable to be the basis this long-term strategy.
The three "Lenses" approach to the strategy is based on existing transport routes/corridors
focused on work opportunities in the city of Bristol, without consideration for location of
new/additional communities, is a further example of short-term thinking.
Why no thought of new, South Gloucestershire, based work locations, able to contribute to our Authorities coffers? Establishing new employment locations, could facilitate the development of additional communities, complying with the climate change agenda and thereby alleviating the additional transport journeys/congestion, which the current approach will obviously generate.
In order to accommodate the housing numbers published in this Consultation, SGC will have to spend money on infrastructure. Thought and consultation needs to focus on which areas would benefit most, and represent the best use of that money!
The introduction of increased housing into communities must consider "up-front" the impact on those areas and provision of essential infrastructure requirements to be provided at construction stage — a subject well-aired at the "pop-up" session I listened into, particularly affecting residents in Frenchay and Filton.
A promise to "do better" was the Chairman’s response, but these issues need early, detailed
attention, not "left to chance"!
Section 3: Emerging Spatial Strategy
Do you have any comments on the provision of additional supply to ensure greater flexibility to meet South Gloucestershire’s housing needs, as set out in section 11 of the Topic Paper? Please also include comments about any individual sites listed at Table 1 at paragraph 11.1 and Appendix 1B.
This Consultation document has been prepared on the basis of "plugging" an undefined housing need. As previously stated, the actual categories / type of accommodation required by the population of South Gloucestershire in the next 15 years, has to be examined in greater depth to meet the "actual" housing requirements and to comply with SGC core policies, particularly those regarding Climate Change.
To achieve the goals of meeting the "actual" housing need and comply with the Climate Change agenda, more "vision" is required.
For example, why can’t priority be given for new accommodation:
* Constructed over SGC owned car parks/ other locations of SGC property
* Integrated with Tech Work hubs.
* Prioritised on Brownfield sites — e.g. Kleeneze in Hanham, which has been firmly left "on back burner".
Satisfying an unsubstantiated housing requirement cannot be imposed on areas of open land, without consideration of the environment they’ll impact.
South Gloucestershire Council’s own Climate Change Core Strategies cannot be over-ridden and must be taken into consideration, together with the provision of comprehensive proposals for a Transport Network, which is required to facilitate an integrated, sustainable future for these additional housing numbers.
Communities need to be formed, with amenities, established transport routes, the right
infrastructure and work opportunities, necessary to comply with the sustainability aspirations of South Gloucestershire Council.
Where is the imagination to anticipate future working opportunities — such as the creation of "High Tech" work hubs, in proximity of existing facilities, and recommended distance to
locations served by public transport?
One overarching question, not addressed by the Consultation documentation is, by reliance on speculative housing companies to deliver the housing numbers required, How will SGC induce House Builders to develop these proposed sites, within the timescale envisaged ? — It's the confluence between a fictitious "demand" and "reliance on commercial enterprise!"
Section 4: Bristol City
Do you have any comments on the Council’s approach to considering whether it can assist with Bristol City Council’s (BCC) unmet housing need, as set out in section 12 of the Topic Paper?
We fully agree with the decision of SGC not to support the housing need of Bristol City Council.
The resolution of the obvious housing needs of South Gloucestershire Council (although not
adequately demonstrated in the Consultation Documentation) must be their priority.
Bristol City Council appears to have prioritised the provision of student accommodation, which has dominated the refurbishment of excess commercial/retail space, etc, within the city, to the detriment of their own pressing housing needs, as all of these developments could have provided much needed family accommodation.
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The Regulation 18 - Local Plan Topic Paper for Housing Land Supply and Bristol Unmet Need Consultation is open until Friday 13th September and we would encourage you to make your views known to South Gloucestershire Council by following this link:
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