9734069 1 SG70 Land East of Abson Road Pucklechurchpdf.Pdf

2. YOUR DETAILS

Name Alan Williams

Company/Organisation Planning Potential (if applicable)

Address

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 Landowner / developer please provide client name and address details:

I (or my client)… Is sole owner of the site [ X ] Owns part of the site [ ] Do not own (or hold any legal interest in) the site whatsoever [ ]

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

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

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

8. ADDITIONAL COMMENTS

If necessary, please continue on a separate sheet and attach to this form.

See enclosed supporting letter

Completed forms, site location plans and any supporting information (Title and deeds etc.) should be emailed to: [email protected].

The site is located in Flood Zone 1 and is not known to be contaminated. There are trees and hedges located to the east of the site abutting the adjacent properties. The site can be accessed from Abson Road.

The site is located outside of, but immediately adjacent to, the Pucklechurch village settlement boundary, and it is positioned on the eastern fringe of Pucklechurch. Accordingly, the development of the site would not add to the coalescence of Pucklechurch with the eastern fringe of Bristol.

The site is bound by Abson Road to the west, and adjoined by Hodden Lane to the South. The site is bordered to the south and east by farmhouses .

Representation

Planning Practice Guidance confirms that site allocation is an important part of the Local Plan process and that an assessment of land availability should identify a future supply of land which is suitable, available and achievable over the plan period. The previous representations for the allocation of the site demonstrate how the Land East of Abson Road, Pucklechurch meets these three criteria.

A summary of the justification for the allocation of land east of Abson Road, Pucklechurch for housing development has been included below, and in the enclosed representations to the West of England Joint Spatial Plan (Publication Draft).

Suitability

The current evidence base for the South Gloucestershire Development Plan shows that the Council does not have a five year housing land supply. Furthermore, previous representations to the emerging Local Plan and the Joint Spatial Strategy have outlined that the forecast housing requirement is not ambitious, and does not take into account the current and historic under delivery of housing in the area.

It is considered that this existing and likely future deficit can be met through the promotion of suitable and sustainable Green Belt sites for residential development. It is considered that a strategic approach to assessing the Green Belt needs to be adopted, rather than assessing individual sites for release, in order to satisfy housing needs of the West of England area, including South Gloucestershire.

emerging Development Plan documents are located to the west of the village. However, development to the west of Pucklechurch would result in the coalescence of Pucklechurch and Bristol. The development of land to the west of Pucklechurch is therefore clearly contrary to paragraph 80 of the NPPF.

On this basis, land east of Abson Road and land at Marsh Farm in Pucklechurch, which are located to the east of Pucklechurch, are the most appropriate location for additional residential development within the village. Furthermore, the site is within 800m of various existing community facilities, which include a community centre, GP surgery, local convenience, and post office.

In relation to housing land supply in Pucklechurch, we are aware that land within the Pucklechurch settlement boundary with extant planning permission for 50 houses has been reallocated as a town and village green. There are now no sites suitable for the required level of housing within the settlement boundary. Therefore, sustainable locations adjacent to the settlement boundary, which includes land east of Abson Road, should be considered.

On the basis of the above information, we would urge the Council to seriously consider this site as a residential allocation within the emerging South Gloucestershire Local Plan.

Availability

The site is owned by and there are no legal or ownership constraints. The landowner fully supports these representations that have been made on their behalf. There are no issues relating to availability of the site that would impact upon its delivery for housing within the plan period.

Achievable

An application for residential development on this site could be progressed and submitted in the near future. Should the site be successfully allocated, it is anticipated that the delivery of homes could be within the next 5 years, contributing to the significant housing requirement in the area.

Conclusion

This representation is submitted by Planning Potential, on behalf of in response to the consultation on the South Gloucestershire Local Plan .

The site is suitable, available, and achievable for residential development for the reasons as set out above. Although the site is located within the Green Belt, it is considered the release of the site is required to address the extensive need for new housing within the draft West of England Joint Spatial Plan and South Gloucestershire Local Plan, and the trend of under delivery in the Local Authority Area.

The site is in a sustainable location adjacent to the east of the Pucklechurch village settlement, and is well served be existing amenities. The site could come forward for development within 5 years.

We trust you will give this representation due consideration. Should you have questions or queries, please do not hesitate to contact me.

Yours faithfully,

Alan Williams

Associate

Planning Potential Bristol

Enc.

of a wider area belonging to the Forest of Avon Trust; a local charity for trees for the West of England. The site is not covered by any further designations.

As stated above, it is acknowledged that the site is located within the Green Belt. However, due to its location to the east of Pucklechurch, the site would not add to the coalescence with the east of Bristol, ensuring that the opportunity for urban sprawl is contained.

There are currently no known physical limitations that would impact upon the suitability of the site for residential development. For instance, the site is within Flood Zone 1. The site is not known to be contaminated or polluted. The site is not within a conversation area or an area of archaeological potential. The site can be easily accessed via Abson Road, so there are few accessibility issues to overcome.

Although the site is not located within the Pucklechurch village settlement boundary, it benefits from being located directly adjacent to it and is therefore well serviced by the amenities and services found within Pucklechurch itself. The site is located 0.8km away from Pucklechurch Church of England Primary School, and the village includes a range of amenities including a newsagent and post office, all located within 0.5km of the site. The site is within a short 5 minute walking distance to the closest bus stop located only 0.6km away, with bus services connecting it to the wider Bristol area. A key objective of the draft West of England Joint Spatial Plan is to promote sustainable development by ensuring that residential development is located within close proximity to sustainable transport and existing urban centres. It is considered that the site meets these key criteria.

Farmhouses and other dwellings are located to the southern and eastern boundaries of the site. Therefore, the principle of development to the east of Abson Road is established, and these parcels of land should be considered previously developed land. Paragraph 89(4 and 6)) and of the NPPF considers development on previously developed land to be considered acceptable. Soundness of the West of England Joint Spatial Plan

This representation to the Publication Draft of the JSP has been submitted principally in response to the identified housing requirement (based on the Wider Bristol HMA (WBA) and the B&NES HMA SHMA’s) as set out in Topic Paper 1, and the achievability of the housing requirement for South Gloucestershire included at Policy 1 of the JSP.

In addition, this representation includes comment on the robustness of the Strategic Development Locations, particularly in South Gloucestershire, that are identified at Policies 2 and 7 of the JSP and Topic Paper 2. It demonstrates why land at Pucklechurch, whilst not representing a Strategic Development Location, should be included within the JSP for housing development to meet identified need.

Housing Requirement Paragraph 23 of the JSP Publication Document and paragraphs 2.4 and 3.1 of Topic Paper 1 from the JSP evidence base confirm that the SHMA’s for the WBA HMA and the B&NES HMA include an Objectively Assessed Housing Need (OAHN) of 97,800 dwellings within the JSP boundary over the Plan Period.

On the basis of an OAHN of 97,800 dwellings, Topic Paper 1 and Policy 1 of the Publication Draft JSP advise that the evidence- based need for housing (the Housing Target) is, therefore, 102,200 new dwellings.

Paragraph 3.2 of Topic Paper 1 continues to advise that “…in light of the advice in NPPF para 14, the JSP seeks to provide flexibility by increasing the OAHN between 5% to 10%” . As a result, Policy 1 of the JSP includes an overall target of 105,500 new dwellings, which equates to approximately 7.5% flexibility on the OAHN.

The Publication Document identifies that a key challenge for the JSP is how to accommodate and deliver much needed homes in the West of England. At 5,861 new dwellings per annum, it is considered that the objectively assessed JSP target of 105,500 new dwellings to 2036 does not represent an ‘ambitious strategic response’ to this issue, as identified at Chapter 1 Paragraph 1 of the JSP Publication Document.

Furthermore, there is not guarantee that all the significant number of committed dwellings (61,500) will come forward.

It is considered unrealistic to assume that any lack of development in South Gloucestershire (for example) could be accommodated within any of the other three authority areas. Therefore, the JSP is currently at risk of failing to meet the OAHN identified within the SHMA, Topic Papers and other evidence base documents.

South Gloucestershire’s 2017 Authority’s Monitoring Report (AMR) confirms that at December 2017, the Council’s five year housing land supply was 4.66 years. In addition, the AMR identifies that of the 28,355 new homes required by Core Strategy Policy CS15 over the Development Plan period, only 10,866 of these homes were built between April 2006 and March 2017. Therefore, a minimum of 17,489 new homes (nearly twice what was built in the previous 10 years) are required over the remaining 10 years of the Plan to 2027.

Diagram 1 from Topic Paper 1 identifies that whilst South Gloucestershire saw an increase in housing delivery in 2016/2017, the average annual housing delivery between 2006 to 2017 was only 989 dwellings. This is considerably below the target of 1,806 dwellings per annum set by the JSP.

On this basis, not only it is considered that South Gloucestershire Council is unlikely to meet its five year housing land requirement, there is a risk that the Council will be unable to deliver the 32,500 new dwellings required by Policy 1 of the Publication Draft JSP over the plan period to 2036 without additional sites.

Accordingly, it is considered that the delivery of new dwellings within the Publication draft JSP has not taken sufficient account of the existing performance of the four authorities. This is contrary to Paragraph 185 of the NPPF, which requires new Plan’s to be based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.

Therefore, in its current form, the JSP cannot be considered to be sufficiently justified, effective or in accordance with national policy on actual delivery of the market and affordable housing set out in the WBA and B&NES HMA’s.

For the above reasons, it is considered that the current Publication Draft West of England JSP is unsound.

Additional Housing Development Locations Policies 2 and 7 of the JSP identify broad Strategic Development Locations for the new Local Plan, including Buckover, Charfield, Coalpit Heath, Thornbury, and Yate in South Gloucestershire. This representation does not specifically comment on the suitability and sustainability of the proposed Strategic Development Locations that are identified in the Key Diagram (Figure 7) at Appendix A of the JSP Publication Document.

Rather, it is demonstrates that the Council should adopt a comprehensive approach when assessing the suitability of the land at Pucklechurch for housing delivery whilst establishing that land at Pucklechurch represents a highly sustainable location which should be acknowledged for housing development in South Gloucestershire within the JSP. This is by reason of its proximity to the developed area of Pucklechurch.

Due to the sustainable location of land at Pucklechurch it is considered that the development of the land is consistent with Policies 5 and 6 of the JSP Publication Draft relating to the protection and enhancement of the natural, built and historic environment, and ensuring that new development is properly aligned with the provision of the necessary strategic infrastructure.

It has been identified above that South Gloucestershire Council is not meeting its five year housing targets, and Paragraph 49 of the NPPF confirms that “Relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites” . Furthermore, The Supreme Court decision of Suffolk Coastal District Council v Hopkins Homes Ltd & Anor [2017] UKSC 37 confirms that any shortfall in the housing supply is enough to trigger the operation of the second part of paragraph 14, which requires the grant of planning permission

unless any adverse impacts would significantly and demonstrably outweigh the benefits, or specific policies in this Framework indicate development should be restricted.

Residential development located adjacent to land at Pucklechurch is characterised by terraced and semi-detached housing. Therefore, this land could be developed without unacceptable effects on occupiers and neighbouring areas, and strong landscape boundaries can be established. The land is owned by and there are no legal or ownership constraints preventing delivery. Moreover, the landowner fully supports these representations that have been made on their behalf. There are no issues relating to availability of the land that would impact upon its delivery for housing. In addition, an application for residential development on this land could be progressed and submitted in the near future. It is also likely that this is the case for the adjacent land owned by Should the land be successfully included within the JSP, it is anticipated that the delivery of homes could be within the next 5 years, contributing to the significant housing requirement in the area.

Furthermore, the proposed development of housing on land at Pucklechurch has been carefully calculated to ensure that the proposed strategic development is not only sustainable, but also provides a viable development that can be delivered in the short term. The inclusion of additional housing at Pucklechurch within the JSP and new South Gloucestershire Local Plan will assist in meeting the housing land supply for the West of England.

It is acknowledged that land at Pucklechurch is within the Greenbelt and that “…inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances” (NPPF, Para. 87). However, the case of Calverton Parish Council v Nottingham City Council, Broxtowe Borough Council and Gedling Borough Council [2015] EWHC 1078 (Admin), Jay J confirms that suitability and availability, which have both been demonstrated for land at Pucklechurch, are sufficient to constitute exceptional circumstances (subject to various refinements). These principles are reflected within the Council’s Policy CS5(6) of the adopted Core Strategy, which states that whilst the Green Belt should remain unchanged, other proposals for development in the Green Belt will need to comply with the provisions in the NPPF.

In addition, Chapter 4 Paragraph 12 of the JSP Publication Document advises that there are exceptional circumstances to justify the release of certain locations from the Greenbelt, and the JSP does include some Strategic Development Locations within the Greenbelt. Moreover, Policy 2 of the JSP Publication Document confirms that the general extent of the Greenbelt is maintained except where it is required to be amended through local plans to enable the delivery of the Strategic Development Locations at Coalpit Heath, North Keynsham, Yate, Bath Road, Brislington and Whitchurch. Therefore, the principle of development in the Greenbelt is established.

The case of Gallagher HomesHomes Ltd v Solihull Borough Council [2014][2014] EWHC 1283 (Admin), Hickinbottom J confirms that there is no test that Greenbelt land is to be released as a last resort. It is an exercise of planning judgment as to whether exceptional circumstances necessitating revision have been demonstrated. On the basis of the above, it is considered that the inclusion of land at Pucklechurch for housing development within the JSP would provide an appropriate strategy for development in South Gloucestershire.

Conclusion

This representation is submitted by Planning Potential, on behalf of in response to the consultation on the West of England Joint Spatial Plan Publication Document.

This representation provides comment on the soundness of the JSP, and demonstrates that for ambitious levels of growth for the West of England, in particular South Gloucestershire, and to deliver sufficient levels of sustainable housing developments, additional development locations ought to be identified.

Although land at Pucklechurch is located within the Greenbelt, it is in a sustainable location adjacent to the east of the Pucklechurch village settlement, and is well served by existing amenities. In addition, the land could come forward for development within 5 years. Therefore, it has been demonstrated that the release of the site is required to address the extensive need for new housing within the West of England.

Furthermore, we are aware that previously promoted Land at Marsh Farm, which surrounds our Client’s land. Therefore, it is considered that the Council should adopt a comprehensive approach when assessing the suitability of the land at Pucklechurch for housing delivery.

In summary, for the reasons set out in this representation, it is considered that the JSP is currently not sufficiently justified, effective or in accordance with national policy, and is unlikely to deliver the amount of residential development that is required to the meet the anticipated levels of growth.

Therefore, it is considered that the current Publication Draft West of England JSP is unsound.