South Gloucestershire Council New Local Plan Site Submission Form

GUIDANCE ON COMPLETING THIS FORM

Please return this form if you are suggesting a site to be considered in the New South Gloucestershire Local Plan. Previously submitted sites are available to view on an online map at: www.southglos.gov.uk/callforsites

For each site please complete a separate form and provide a map that clearly and accurately identifies the site boundary.

Completed forms and site location plans should be emailed to: [email protected].

Identifying a potential site does not infer that the council in any way supports the development of the site. Sites will be assessed through the plan making process and will be subject to normal planning procedures.

Data Protection Statement: This information is collected by Bath and North East Somerset Council, Bristol City Council, North Somerset Council and South Gloucestershire Council as data controller in accordance with the data protection principles in the Data Protection Act 1998. The purposes for collecting this data are: to assist in plan making, to contact you, if necessary, regarding the answers given on this form, and to keep you informed of progress with plan making. Some of the data relating to specific sites will be made public as it will form part of the evidence base used to inform the creation of planning policy documents. The above purposes may require public disclosure of any data received on the form, in accordance with the Freedom of Information Act 2000.

. 1. HAS THE SITE PREVIOUSLY BEEN SUBMITTED TO THE COUNCIL? Previously submitted sites are available to view on the online map accessible from: www.southglos.gov.uk/callforsites (Click on the site to see the site reference number and information previously submitted).

Please enter the relevant Site Reference number from www.southglos.gov.uk/callforsites Has this site previously been Yes SGJSPIO013: Land to the east of Morton Way, submitted? Thornbury

SG000184: Land to the east of Morton Way, Thornbury

If the site has already been submitted, how does the information provided in this form change the information you have previously provided to us? The site was submitted to the JSP call for sites on behalf of the landowner. Bovis Homes Limited now controls the site in its entirety. Additional information is now available in respect of the suitability, availability and deliverability of the site.

1 2. YOUR DETAILS Name Sarah Fordham

Company/Organisation GL Hearn (if applicable)

Address GL Hearn Queen Square House 18-21 Queen Square Bristol BS1 4NH

Telephone

Status (please tick all that Owner of (all or part of) the site [ ] Land Agent [ ] apply Planning Consultant [X] Developer [ ] Amenity/ Community Group [ ] Local Resident [ ] Registered Social Housing Provider [ ] Other (please specify) [ ]

If acting on behalf of Bovis Homes Limited Landowner / developer Bovis Homes Western Regional Office please provide client name Cleeve Hall and address details: Cheltenham Road Bishops Cleeve Cheltenham GL52 8GD

I (or my client)… Is sole owner of the site [Bovis Homes has a legal interest in the site (Option Agreement)] Owns part of the site [ ] Do not own (or hold any legal interest in) the site whatsoever [ ]

If Owner/Part Owner, have Yes [ ] No [X] you attached a title plan and deeds with this form?

If you are not the owner, or own only part of the site, do you know who owns the site or the remainder of it (please provide details)?

2 Does the owner (or other Yes [X] No [ ] owner(s)) support your proposals for the site?

3. SITE DETAILS

Site Address (including Land south of Gloucester Road, Thornbury postcode where applicable) 365219 191277

Site Area (Hectares)(if known) c. 26.5ha

Current land use(s) Agricultural

Adjacent land use(s) Residential and agricultural.

Relevant planning history (if known) PT16/037/SCR – Screening Opinion for residential development up to 400 dwellings.

PT16/049/SCO – Scoping Opinion for residential development up to 400 dwellings.

Please tick box to confirm you have provided a site plan [X]

4. POTENTIAL USES & CAPACITY Suggested uses (please tick all that apply and where mixed use indicate % of overall site for each use)

USE Capacity (number of units) and indication of possible residential tenures, types and housing for different groups Residential Yes Up to 400 dwellings to include a mix of housing types and tenure, including a proportion of affordable housing.

USE Floorspace (m2) / number of floors/pitches / notes Office, research & development, No light industrial (B1) General industrial (B2) / No warehousing (B8) Sports / leisure (please specify) Yes On site public open space (informal and formal) to be agreed. Retail No

Gypsy and Travellers / No Travelling Showpeople sites

Other (please specify) No

3 Additional notes about potential uses:

Bovis Homes would welcome the opportunity to discuss the land use with South Gloucestershire Council.

5. SITE SUITABLITY ISSUES

Question Further details including details of further studies undertaken / mitigation proposed Does the site have any physical No The site is informed by a full suite of baseline constraints (e.g. topography, access, studies. severe slope, vegetation cover etc.)?

Is the site subject to flooding? Yes The majority of the land lies within Flood Zone 1 but there is a strip of land within Flood Zone 3 where the watercourse dissects the site in a north-south direction. The Concept Plan locates all development on Flood Zone 1 land. Is the site affected by ‘bad neighbour’ No uses (e.g. power lines, railway lines, major highways, heavy industry)?

Is there a possibility that the site is Yes - None of significance. Up to 2.9m of Made Ground contaminated? partially comprising putrescible material with the potential to generate ground gases was recorded in a small area of the site. It is anticipated that plots constructed within the vicinity of the landfill will require gas protection measures incorporated into the floor slabs, furthermore areas of soft landscaping within the landfill area are anticipated to require the installation of a clean cover system. Can satisfactory vehicular access to the Yes Access drawings have been commissioned and can site be achieved? be made available on request.

Has the Highways Agency been Yes Scoping reports have been submitted to both the consulted? Highway Authority and Highways England.

Is the site subject to any other key No There are no heritage assets within the site but constraints? there are listed buildings nearby that give rise to mitigation proposals within the Concept Plan. Design work is at an advanced stage and can be made available on request.

UTILITIES / INFRASTRUCTURE PROVISION Please tell us which of the following utilities are available to the site

Mains water supply [ ] Mains sewerage [ ] Electrical supply [ ] Gas supply [ ] Landline telephone [ ] Broadband internet [ ] Other (please specify below) [X]

Please provide any other relevant information relating to site suitability issues: Utilities are available adjoining the site and the site can be made fully serviceable.

4 6. SITE AVAILABILITY ISSUES

Question Comments/further details Are there any legal/ownership constraints No on the site that might prohibit or delay development of the site (e.g. ransom strip/covenants)?

Must land off-site be acquired to develop No the site?

Are there any current uses which need to No be relocated?

Is the site owned by a developer or is the Yes Bovis Homes Limited controls the site. An owner willing to sell? option agreement is in place.

Estimated delivery rate: When do you think the site would come forward for development? (Where a development will be phased over more than one period please indicate this)

Within the next 5 years 6-10 years 11-20 years

X X

Do you have any information to support when the site will come forward and its phasing? Please consider suitability, achievability and constraints. Bovis Homes has instructed a full design team and baseline and design work to inform an outline planning application is at an advanced stage.

7. SITE ACHIEVABILITY ISSUES

Question Comments/further details Are there any known significant abnormal No development costs (e.g. contamination remediation, demolition, access etc.)? If yes, please specify. Does the site require significant new No infrastructure investment to be suitable for development? If yes, please specify. Are there any issues that may influence the No economic viability, delivery rates or timing of the development? If yes, please specify. Has a viability assessment / financial Yes appraisal of the scheme been undertaken? Have any design work studies been Yes A full suite of baseline assessments have undertaken? been undertake. An outline application and Environmental Statement is in preparation.

8. ADDITIONAL COMMENTS

5 If necessary, please continue on a separate sheet and attach to this form. For further details please refer to our representations to the New Local Plan Prospectus document submitted on behalf of Bovis Homes Limited.

Completed forms and site location plans should be emailed to: [email protected].

Road Gloucester

Gloucester Road

Lane

Crossways

Morton 0m 20 40 60 80 100

Rev Description Date

Way

Tithe Barn, Barnsley Park Estate, Barnsley, Cirencester, Lane Gloucestershire, GL7 5EG t 01285 740427 e [email protected] w www.edp-uk.co.uk

Crossways client Bovis Homes

project title Gloucester Road, Thornbury

drawing title Site Boundary

date 09 September 2016 drawn by RB drawing number EDP3255/07a checked TJ scale 1:2000 @ A1 South Gloucestershire Council New Local Plan Site Submission Form

GUIDANCE ON COMPLETING THIS FORM

For each site please complete a separate form and provide a map that clearly and accurately identifies the site boundary.

Completed forms and site location plans should be emailed to: [email protected].

Please enter the relevant Site Reference number from www.southglos.gov.uk/callforsites Has this site previously been Yes SGJSPIO013: Land to the east of Morton Way, submitted? Thornbury

SG000184: Land to the east of Morton Way, Thornbury

1 2. YOUR DETAILS Name Sarah Fordham

Company/Organisation GL Hearn (if applicable)

Address GL Hearn Queen Square House 18-21 Queen Square Bristol BS1 4NH

Telephone

If Owner/Part Owner, have Yes [ ] No [X] you attached a title plan and deeds with this form?

If you are not the owner, or own only part of the site, do you know who owns the site or the remainder of it (please provide details)?

2 Does the owner (or other Yes [X] No [ ] owner(s)) support your proposals for the site?

3. SITE DETAILS

Site Address (including Land south of Gloucester Road, Thornbury postcode where applicable) 365219 191277

Site Area (Hectares)(if known) c. 26.5ha

Current land use(s) Agricultural

Adjacent land use(s) Residential and agricultural.

Relevant planning history (if known) PT16/037/SCR – Screening Opinion for residential development up to 400 dwellings.

PT16/049/SCO – Scoping Opinion for residential development up to 400 dwellings.

Please tick box to confirm you have provided a site plan [X]

4. POTENTIAL USES & CAPACITY Suggested uses (please tick all that apply and where mixed use indicate % of overall site for each use)

Gypsy and Travellers / No Travelling Showpeople sites

Other (please specify) No

3 Additional notes about potential uses:

Bovis Homes would welcome the opportunity to discuss the land use with South Gloucestershire Council.

5. SITE SUITABLITY ISSUES

Has the Highways Agency been Yes Scoping reports have been submitted to both the consulted? Highway Authority and Highways England.

UTILITIES / INFRASTRUCTURE PROVISION Please tell us which of the following utilities are available to the site

Mains water supply [ ] Mains sewerage [ ] Electrical supply [ ] Gas supply [ ] Landline telephone [ ] Broadband internet [ ] Other (please specify below) [X]

Please provide any other relevant information relating to site suitability issues: Utilities are available adjoining the site and the site can be made fully serviceable.

4 6. SITE AVAILABILITY ISSUES

Question Comments/further details Are there any legal/ownership constraints No on the site that might prohibit or delay development of the site (e.g. ransom strip/covenants)?

Must land off-site be acquired to develop No the site?

Are there any current uses which need to No be relocated?

Is the site owned by a developer or is the Yes Bovis Homes Limited controls the site. An owner willing to sell? option agreement is in place.

Estimated delivery rate: When do you think the site would come forward for development? (Where a development will be phased over more than one period please indicate this)

Within the next 5 years 6-10 years 11-20 years

X X

7. SITE ACHIEVABILITY ISSUES

8. ADDITIONAL COMMENTS

Completed forms and site location plans should be emailed to: [email protected].

Road Gloucester

Gloucester Road

Lane

Crossways

Morton 0m 20 40 60 80 100

Rev Description Date

Way

Tithe Barn, Barnsley Park Estate, Barnsley, Cirencester, Lane Gloucestershire, GL7 5EG t 01285 740427 e [email protected] w www.edp-uk.co.uk

Crossways client Bovis Homes

project title Gloucester Road, Thornbury

drawing title Site Boundary

date 09 September 2016 drawn by RB drawing number EDP3255/07a checked TJ scale 1:2000 @ A1 Our ref: 170223 J035415sf_NLP_reps_final Your ref: New Local Plan

Strategic Planning Policy and Specialist Advice Team South Gloucestershire Council Department for Environment and Community Services PO Box 299 Civic Centre High Street Kingswood Bristol, BS15 0DR

23 February 2017

Dear Sir/ Madam

SOUTH GLOUCESTERSHIRE COUNCIL NEW LOCAL PLAN 2018 – 2036: PROSPECTUS

REPRESENTATIONS ON BEHALF OF BOVIS HOMES LIMITED

Introduction

On behalf of our client, Bovis Homes Limited (herein Bovis Homes), please find enclosed our representations to the South Gloucestershire New Local Plan Prospectus document.

Bovis Homes retains an interest in all strategic issues informing the South Gloucestershire New Local Plan. However, these representations are submitted specifically in the context of Bovis Homes’ land interest south of Gloucester Road, Thornbury. Further details relating to the site are included within these representations and an updated Call for Sites pro forma is attached.

Bovis Homes supports the preparation of the New Local Plan (NLP). The NLP will provide a much needed early review of the Local Plan Core Strategy (adopted December 2013), in accordance with the recommendations of the Inspector examining the Core Strategy, and consistent with the intentions set out within the Government’s Housing White Paper (para. 1.8) (February 2017) requiring Plans to be updated in whole or part at least every five years.

These representations follow the structure and respond to the questions contained within the prospectus document.

Question 1: Engagement on cross boundary strategic matters

The preparation the NLP in parallel with the West of England Joint Spatial Plan (JSP) will be key to delivering sustainable development that reflects the vision, aspirations and strategic priorities of the West of England partnership; the Local Enterprise Partnership (LEP) Strategic Economic Plan (SEP); and the West of England Devolution agreement. Bovis Homes supports the collaborative approach taken by the Council and the West of England authorities, in particular in relation to the delivery of the right amount of homes in the Bristol and Bath Housing Market Areas. It is important that this cross boundary working continues in an

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Plan\170223_J035415sf_nlp_reps_FINAL.docx open and pragmatic manner to ensure that the respective Local Plans can be put in place in the most effective and efficient manner, and to secure the timely delivery of new homes.

While the National Planning Policy Framework (NPPF) and the Localism Act places a duty on public bodies to co-operate on planning issues across boundaries, it is also paramount that the Council engages in positive and proactive discussions with all relevant stakeholders, including those parties that have land and other strategic interests in how the Plan’s objectives will be met, and how development will be sustainably and viably delivered. This includes engagement that goes beyond the boundaries of Regulation 18 and 19 consultations, and into more focussed round table and working group discussions.

A key topic that requires open and transparent collaboration is the overall housing requirement figure. The Government’s Housing White Paper indicates that by April 2018 a standardised methodology for calculating the housing requirement will apply as a baseline for assessing five year housing land supply and housing delivery. This topic will, therefore, be at the forefront of an Inspector’s mind during the Joint Spatial Plan and New Local Plan Examinations. While the specifics of this methodology is currently unknown, the Council, alongside its West of England partners, can take proactive steps now by engaging with all relevant stakeholders to reach an industry agreed position on the housing requirement informing the JSP and NLP without leading to unnecessary delays in the preparation of the respective Plans.

Question 2: Key priorities

In principle, Bovis Homes broadly supports the topics contained within draft key priorities set out within Topic Paper 1. However, the following priorities should be amended to more clearly align with the Government’s overarching commitment to support economic growth and to boost significantly the supply of housing nationally; and to align with the vision and strategic priorities contained within the emerging JSP.

2. Maintaining economic prosperity

As drafted, Priority 2 fails to recognise the important role that housing provision plays in supporting sustainable economic growth and is therefore inconsistent with the ambition of the LEP SEP as set out below:

“Providing jobs and homes in the right locations and at the right time, is intrinsically linked to the future economic prosperity of the area. We need to ensure the right conditions for businesses to grow. By providing for a range of housing types, the area will retain and attract the workforce required, which will support sustainable economic growth.

We need to continue to provide housing at priority locations and generally across the region to meet local needs. This includes smart use of small infill/brownfield sites as well as larger strategic housing sites. Our approach is to secure investment in the infrastructure that is required to support more sustainable patterns of growth, and maximise the social and environmental benefits. A planned approach will enable us to target our resources to provide necessary infrastructure that can accelerate the delivery of much needed new homes. Our Economic Plan will enable a faster pace of delivery of homes.”

(Our emphasis)

In addition, instead of ‘maintaining economic prosperity’, the Council’s priority should be to ‘support economic growth’. The vision of the emerging JSP is to make the West of England one of Europe’s fastest growing and most prosperous city regions and this is consistent with the Government’s commitment to

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Plan\170223_J035415sf_nlp_reps_FINAL.docx secure economic growth in order to create jobs and prosperity. The Council’s priority, as drafted, is not ambitious enough to align with the wider strategic objectives of the West of England or the LEP.

3. Providing housing for all

Bovis Homes endorses the principle of providing housing for all. However, this priority should be amended to clearly reflect the Government’s aim to boost significantly the supply of new homes. The Government’s Housing White Paper confirms that there has been no dilution in the target to demonstrably increase the supply of housing. Indeed, the four steps set out within the Housing White Paper further emphasises the need to build more homes quicker:

1. Planning for the right homes in the right places; 2. Building homes faster; 3. Diversifying the market; and 4. Helping people now.

To align with the Government’s steer on significantly increasing the amount of housing and speed of delivery, these principles should be incorporated into the priorities of the New Local Plan.

The priority identifies an affordability gap in South Gloucestershire where house prices have risen compared to incomes making it an expensive place to buy. This affordability gap may in part have been exacerbated by a historic under-supply of housing in South Gloucestershire. The priority therefore needs to set out a clear commitment to avoid the housing land supply problems that have prevailed in the past owing to an over-reliance on large scale urban extensions/new communities where there have been delays in delivering housing to meet the district's needs. A more appropriate balance of large/medium/small scale allocations is required to ensure new homes are delivered in a timely and planned manner.

The Government’s recent Housing White Paper further sets out the intention to introduce a new housing delivery test by, the first stage of which will take place by November 2017. Failure to deliver housing against the delivery test will necessitate the preparation of an action plan including the trigger of policy responses that will ensure that further land comes forward. Given the Council’s record in respect of housing delivery, the New Local Plan should seek to positively react to this test now by identifying potential housing growth over and above its housing requirement, including in respect of contingency sites.

In delivering sustainable communities (which is largely infrastructure driven), the NLP needs to adopt an ambitious but realistic approach to distributing growth within the areas of search identified in the JSP. The primary focus must be on ensuring existing settlements are supported by necessary infrastructure and ensuring development is allocated to these areas to maximise the benefits of the existing infrastructure or justify further investment in infrastructure that would also benefit existing residents. Once growth/infrastructure investment in existing settlements has been addressed, consideration can then be given to infrastructure investment as part of new settlements or major urban extensions.

Additionally, in the interests of preparing a plan that is positive, justified, effective and consistent with national policy, South Gloucestershire should be seeking to meet at least its housing requirement, informed by the work being undertaken in relation to the JSP, to reflect local growth ambitions, and to support economic growth in both urban and rural areas. Without following this fundamental aim the Plan cannot be found sound.

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Plan\170223_J035415sf_nlp_reps_FINAL.docx Question 3: Vision

The Vision is the core component of the Local Plan. It underpins all of the policies and proposals over the plan period and shapes the spatial strategy. National Planning Guidance makes clear that Local Plans should be based on a clear and deliverable Vision which seeks to address needs and opportunities in relation to housing, the economy, community facilities and infrastructure:

“Local Plans set out a vision and a framework for the future development of the area, addressing needs and opportunities in relation to housing, the economy, community facilities and infrastructure…” (Paragraph 001; Reference ID: 12-001-20140306, NPPG)

Paragraph 3.8 of the Prospectus document states that the Council will need to update the Core Strategy vision to reflect the ambitious vision and economic growth ambitions set out in the JSP, to confirm the areas where strategic and local economic and housing growth will take and will not take place, and to include detailed visions for each part of the District. The Prospectus Topic Paper (1) does not at this stage set out a new draft Vision for the Plan period to 2036 and thus it is difficult to comment on how the New Local Plan will align itself to the growth targets set out by the LEP.

The New Local Plan vision should not simply provide an update to the vision contained within the Core Strategy. The Core Strategy precedes the vision and ambitions set out by the four constituent authorities within the JSP and the economic growth ambitions set out by the LEP. The vision contained within the New Local Plan must, therefore, be re-written to align to the ultimate goal for ‘the West of England to be one of Europe’s fastest growing and most prosperous city regions’ as set out within the emerging WoE JSP. At this stage Bovis Homes is concerned that the New Local Plan is not being ambitious enough within its priorities and its vision will therefore fall short of the overarching wider strategic objectives of the WoE.

The vision for Thornbury should reflect the status of the settlement as a sustainable market town, consistent with the findings of the supporting evidence base including the Sustainable Access Profile (January 2017). Thornbury should be seen as a location for strategic and non-strategic growth both in the Plan period to 2036 and beyond, representing a key opportunity to deliver housing and employment growth supported by a range of facilities, and to provide for the housing needs for everyone including young people and the elderly. The vision for Thornbury should be ambitious, forward thinking and set a positive platform to enable the town to grow and to provide a basis for securing additional infrastructure investment. The vision should not set an upper limit on the amount of housing that should be directed to Thornbury as this would undermine the wider growth ambitions of the WoE and conflict with the NPPF requirement for the NLP to be positively prepared and the overall presumption in favour of sustainable development.

The Location Dashboard topic paper1 supporting the recent JSP Emerging Spatial Strategy consultation recognises that there is potential for further housing growth ‘north and south of the existing Morton Way development’. The vision should support further growth to the north and north east of the town within the general vicinity of existing growth and where development has been found sustainable and sound by the Inspector examining the Core Strategy.

The Prospectus document notably omits visions for other areas identified as potential strategic growth locations within the JSP Emerging Spatial Strategy. This includes indicative proposals for a garden village at Buckover. Bovis Homes’ concerns in respect of the Buckover proposals have been set out in detail within its representations to the JSP Emerging Spatial Strategy. It would be reasonable to conclude that an assessment of the merits of the Buckover proposals has recently been provided via the Government’s decision in January 2017 not to include it as one of the chosen locations to benefit from Government

1 WoE JSP Emerging Strategic HELAA Assessment of Strategic Development Locations Beyond Settlement Boundaries

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Plan\170223_J035415sf_nlp_reps_FINAL.docx support as a new garden settlement, and this must be taken as a clear signal that Buckover is not a sustainable or credible development option. Bovis Homes therefore supports the absence of Buckover from the vision of the NLP.

Question 4: Draft structure

The prospectus document implies that the Council is aiming to prepare a Plan that is as high-level and focussed as possible. Bovis Homes supports this approach which is consistent with the National Planning Practice Guidance (NPPG) as set out below:

“…Local Plans should be as focused, concise and accessible as possible. They should concentrate on the critical issues facing the area including its development needs and the strategy and opportunities for addressing them, paying careful attention to both deliverability and viability.”

The NPPG goes on to state that:

“In drafting policies the local planning authority should avoid undue repetition, for example by using generic policies to set out principles that may be common to different types of development. There should be no need to reiterate policies that are already set out in the National Planning Policy Framework.”

In respect of Part 1 of the New Local Plan, paragraph 4.1 of the Prospectus Topic Paper (2) indicates that it will set out the locational visions, locational policies and site allocations consistent with the JSP. It goes on to state that existing (spatial) locational policies and site allocations will be rolled forward from existing adopted Plans. It should be noted, however, the existing allocations and policies contained within the Core Strategy (2013) and Local Plan (saved policies, 2006) should not automatically be rolled forward into the New Local Plan. Each site must be re-examined in respect of its suitability, deliverability and availability within the Plan period. A number of allocations contained within these Plans are showing no signs of being delivered despite being allocated for a prolonged period. Continued reliance on these undeliverable sites will undermine the soundness of the Plan, and will have a direct impact on the Council’s ability to meet its five year housing land supply, or to meet the future housing delivery test set out within the Government’s Housing White Paper.

We note that the New Local Plan will detail ‘non-strategic housing allocations’. However, the Prospectus documents do not include a definition of ‘strategic’ and ‘non-strategic’. In its representations to the JSP Bovis Homes has consistently stated that there should be flexibility within the definition of strategic and non- strategic to ensure that a wide range of sites are brought forward thus maximising housing supply. South Gloucestershire Council has historically relied on large (1000+) urban extensions which have incurred significant delays in deliverability thus leading to the Council’s current position where it is unable to demonstrate a five year supply of deliverable housing. It is important that the Council learns from its past mistakes by allocating a range of sites. Land south of Gloucester Road, Thornbury, which has a capacity of up to 400 new homes, is a good example of a medium scale site that can offer either strategic level or non- strategic growth without reliance on substantial upfront investment (and subsequent time delays) in infrastructure.

The JSP Emerging Spatial Strategy refers to potential ‘growth areas’. The scope of the JSP as it currently stands suggests that it will not allocate specific sites for housing as this role will be fulfilled by each authority’s Local Plan. The New Local Plan will, therefore, not only identify non-strategic housing allocations, but will also allocate (with a red line) strategic housing allocations informed by the locational strategy contained within the JSP. This has not been clearly communicated within Part 4 of the Prospectus Topic Paper (2).

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Plan\170223_J035415sf_nlp_reps_FINAL.docx The prospectus document does not include any potential strategic or non-strategic allocations and this reflects the very early stage in its preparation. Section 5 of the prospectus document lists a number of studies and assessment that will be undertaken to inform the content and allocations contained within the NLP. Bovis Homes supports this approach which is consistent with national planning policy (NPPF, Para 158) and guidance:

“Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.”

However, Bovis Homes is concerned that this approach is not being followed in practice. We are aware, for example, that the Council has undertaken some early initial consultation events in Thornbury where sites have been favoured by the Council for future allocation. Such an approach is not transparent or pragmatic; is prejudicial to the NLP vision and spatial strategy; is not justified; and fails the tests of soundness as set out in paragraph 182 of the NPPF. In preparing the NLP, the Council must continue to consider all possible options for the delivery of housing and economic growth over the Plan period to 2036, including consideration of all reasonable alternatives. The Council must not, at this early initiation stage, be favouring potential developments at, for example Buckover where there is insufficient evidence base to support such an approach.

Questions 5 and 6: Proposed policies and land uses issues

It is noted that the New Local Plan will replace all existing Development Plan Documents including the Core Strategy and the Policies, Sites and Places Plan (PSPP), the latter of which is yet to be adopted and is currently subject to Examination. The Prospectus document implies that where possible existing policies will be carried forward. This approach is not robust. As set out above, the New Local Plan and the policies contained within it must be based on a relevant, up to date and adequate evidence base. The evidence base must inform the New Local Plan and thus it not satisfactory to simply carry forward policies from previous Plans. The Council must fully scrutinise each policy to ensure that it is relevant, does not repeat policies already contained within the NPPF, and is consistent with Government guidance and legislation. In particular, the Council must ensure that its NLP provides enough flexibility within its policies to support economic growth, and to adapt to rapid change.

Question 7: Call for sites – Land south of Gloucester Road, Thornbury

Land south of Gloucester Road is located on the north eastern fringe of Thornbury, approximately one mile from Thornbury Town Centre. It adjoins the boundary of the ‘Thornbury Fields’ residential-led development to the east of Morton Way within the area of existing identified growth. The site falls within the area of potential strategic growth to the ‘north and east of Thornbury’ as set out in the Joint Spatial Plan Emerging Spatial Strategy2

The site extends to 26.5ha as outlined on the enclosed site location plan. The site was submitted to South Gloucestershire’s Call for Sites in January 2015 by the landowner (JSP Site Reference SG000184). In the meantime, Bovis Homes has acquired a land interest in the site.

2 WoE JSP Emerging Strategic HELAA Assessment of Strategic Development Locations Beyond Settlement Boundaries

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Plan\170223_J035415sf_nlp_reps_FINAL.docx The site does not form part of the Green Belt nor does it lie within a nationally or locally designated landscape. The majority of the site is located within Flood Zone 1; there is a narrow strip of land to the east of the site affected by Flood Zones 2 and 3 which is excluded from the developable area of the site.

Bovis Homes has appointed a full design team and technical and design work is at an advanced stage. Emerging proposals provide for residential development of up to 400 new homes; an expansive landscape framework; access onto Gloucester Road; and a suite of on-site mitigation proposals that address potential heritage, drainage, transport and environmental concerns. While site specific constraints exist, the site is sufficiently sized to mitigate any adverse impacts. The preparation of an Environmental Statement, which includes consideration of cumulative site impacts, is also well underway, informed by the scope provided by the Council. Further details relating to the emerging proposals can be made available to South Gloucestershire Council on request.

Land south of Gloucester Road is available now, offers a suitable location for development now, and is achievable with a realistic prospect that new homes will be delivered on the site within five years. Bovis Homes controls the site in its entirety and is a leading UK housebuilder Bovis Homes with a track record of delivering new homes nationally and regionally.

Questions 8 and 9: Sustainable Access Profiles

Bovis Homes offers the following observations in respect of the Sustainable Access Profiles and Methodology:

 Unlike the Sustainable Access to Key Services and Facilities & Demographic Information Topic Paper (November 2015), the Sustainable Access Profile (January 2017) does not provide analysis on the findings of the assessment. For example, the earlier assessment ranked the settlements and provided a score based on access to key services and facilities. Thornbury scored 40/40 and was ranked in ‘Tier 1’ reflecting its high degree of sustainability and suitability for future strategic and non-strategic growth. This analysis is extremely useful for determining which settlements (i.e. Thornbury) should be considered a priority area for growth and should be reflected again within the latest assessment.  The most recent methodology excludes Hospitals and Leisure Centres from analysis given that they are unlikely to be within walking distance in the majority of instances. This approach is not robust. Hospitals and leisure centres are key services within a settlement. Those settlements that have access Hospitals and leisure centres, such as Thornbury, should be recognised as significantly more sustainable and favourable for future growth than those that do not have those services (for example Charfield, Coalpit Heath, and Buckover).  It is important that when interpreting the analysis, the Council retains a degree of flexibility and ‘common sense’. For example, when interpreting the suitability of potential allocations, the Council should not automatically exclude developments that fall just short of the walking and cycling distance analysis used in the methodology. Such sites are more likely to be more sustainable than new settlements or major urban extensions to small suburban settlements where much of the social infrastructure will need to be deferred to later phases of development owing to the up-front costs of delivering critical transport and utility infrastructure.  We note that the Council intends to assess access to public transport and broadband under a separate methodology approach. However, access to public transport in particular forms a critical component of how sustainable a settlement is and should be incorporated into the Sustainable Access Profile.  The Sustainable Access Profile for Thornbury does not include the consented retail unit on land at Morton Way North and should therefore be amended to include this future facility.

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