Green Belt Exceptional Circumstances – Overarching Issues and the Relationship Between the JSP and Local Plans (Polices 2 and 7.1-7.2)

HEARING STATEMENT

Peter Brett Associates on behalf of IM Land Matter 2: Strategic Development Locations and Green Belt Exceptional Circumstances – Overarching Issues and the Relationship between the JSP and Local Plans (Polices 2 and 7.1-7.2)

Introduction

1. This statement has been prepared by Peter Brett Associates, now part of Stantec (PBA), on behalf of IM Land (IM), regarding the soundness of the emerging West of England Joint Spatial Plan and specifically in response to questions relating to the SDLs and Green Belt exceptional circumstances. 2. IM agree that for sustainability reasons, exceptional circumstances exist to support some growth within the Green Belt, close to the urban locations of Bristol and Bath. 3. IM’s Regulation 19 representations explain in Section 3 and Appendix B, why the selection of the Banwell, Buckover and Churchill SDLs should not have been selected in preference to the alternative SDL at Pucklechurch West which is more consistent with the urban living focus and the infrastructure and jobs around the Bristol north east fringe. 4. IM recognises the JSP is a strategic plan and in accordance with paragraph 157 of the NPPF is proposing to illustrate broad strategic development locations; however, this makes it difficult to test the appropriateness of general areas. In redefining Green Belt boundaries, sometimes it is the defined boundary that determines appropriateness. 5. Infrastructure, particularly transport is an essential ingredient of sustainable development and the selection of SDLs. It is referenced in many parts of the Sustainability Appraisal (SA) process. A strategic plan which is unable to specify necessary strategic infrastructure, or which defers it to other documents is not a justified plan that provides a clear indication of how a decision maker should react (as per NPPF2012 para 154). 6. It is difficult to see how future Local Plans, which are being used as the mechanism for making the formal Green Belt changes can be made exempt for being considered against paragraphs 135-141 of NPPF2018 with regard to the SDLs.

Question 2.1: The 12 strategic development locations and proposed amendments to the Green Belt will be considered in more detail in Matters 7.1 – 7.12. However, have the identified strategic development locations (SDLs) been selected in preference to possible alternatives on the basis of a robust, objective and consistent approach and is the 500- dwelling threshold for the SDLs appropriate?

7. No, IM has expressed concerns about the robustness of each stage of the SA process as part of earlier representations. Three pre-submission SAs have been prepared, in 2015, 2016, 2017 plus an addendum note in April 2018 followed by a Consolidated SA in November 2018 (WED009), which post-dates the submission of Regulation 19 representations in January 2018 and submission of the Publication Plan for Examination. 8. IM’s objections at Regulation 19 stage, about the way the SAs were prepared, remain unanswered in the addendum (SD9L) or the additional appendices which appear to sit alongside the earlier SAs. It also appears that the LPAs recognised the flaws with the SA process by the production of a post submission Consolidated SA (WED009), which appraises 3 new alternative development scenarios plus a re-appraisal of what it describes as the 5 original alternative development scenarios set out in SD9L. In all, WED009 re-writes and replaces what must now be accepted as flawed SAs that were used to guide the preparation of the Submission Draft JSP. 9. IM recognise that limited Main Modifications have now been published, but these do not change the underlying issue that some SDL locations are unsustainable and not consistent with National Policy or

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represent an appropriate, let alone the most appropriate strategy when considered against reasonable alternatives. Its objections at Regulation 19 stage to the selection of Banwell, Buckover and Churchill remain unanswered. In response to question 2.1 the following summary is provided: Robustness 10. The fact that the WED009 (November 2018) is almost a full, post submission re-write of previous SAs demonstrates the WoE accept their original approach was not sufficiently robust. The issue is that the current SA did not guide the pre-submission plan making process. Objectiveness 11. In respect of land at Pucklechurch (omission site) the SA was not objective from the outset. It included land that is not part of IM’s proposals and did not fully explore the benefits of this location. Furthermore, it highlights some of the issues that the first 3 SAs raised in respect of Buckover, Banwell and Churchill. Section 3.2 of IM’s original Regulation 19 representations sets out the benefits of Pucklechurch West. By way of an example to demonstrate the shortcomings, IM’s vision document appended to this statement (Appendix 1) revisits the findings of the Consolidated SA and applies the criteria to the site (excluding wider land that formed part of the M4 to Shortwood site). 12. To further illustrate the point, extracts from the SA scores set out in document SD9G Appendix G is provided in Appendix 2 to show how Pucklechurch West performs more sustainably when compared with Banwell, Buckover and Churchill. 13. For a site which is more consistent with the urban living focus (being on the north eastern edge of Bristol), it is unclear why it was dismissed very early in the plan preparation process. Consistent 14. As set out in IM’s Matter 1 Hearing Statement (Q.1.4(c)) there are inconsistencies in the way the SA was used to assess potential SDLs. These are also set out in IM’s Regulation 19 representations (paras 2.4.43-2.4.55), with one such inconsistency being that potential SDL assessments are inaccurate and unjustified. 15. The SDLs of Banwell and Churchill are located a greater distance from the nearest urban centre with poorer sustainable transport connections to existing services and facilities than other locations yet have been scored better. For example, Banwell and Curchill SDLs scored higher for SA categories 2c (access to community facilities), 2d (access to education) and 2e (access to town centres) than West Pucklechurch. However, Banwell and Churchill are located approximately 8km and 11km from the centre of Weston-super-Mare respectively, whereas West Pucklechurch is approximately 2km from the new Emersons Green centre. 16. Furthermore, it was placed in the “dispersed” locational typology even as late as April 2018, despite being near to both Emersons Green centre and Emersons Green Enterprise Zone with good existing sustainable transport connections and opportunities for further improvements. 17. It is therefore not clear how the location assessments and scoring has been carried out consistently across all of the potential SDL sites. 18. With particular regard to the Green Belt assessment, the consultation document is clear that it is not possible to sustainably accommodate all the identified West of England growth needs entirely outside the Green Belt. Thus some development will need to take place within the Bristol and Bath Green Belt. In reviewing the JSP assessment methodology and summary, there are four overarching matters which indicate the process has not been undertaken in a robust and consistent manner: a) With regard to Green Belt Purpose 1, the authors have conflated ‘unrestricted sprawl’ issues with coalescence. This approach evidently does not correlate to Green Belt Purpose 1, nor the methods; and b) Conversely, with specific reference to cells 26b and 26c to the west of Pucklechurch, and with regard to Purpose 2, the authors have accepted that the land between Bristol and Pucklechurch does not contribute to the purpose of preventing the ‘merging’ of towns; c) In relation to the role of the landscape between Yate and Coalpit Heath SDLs, very little weight appears to have been given to the manner in which growth might be perceived from the adjoining landscape as part of a combined release where there could be up to a 50% reduction

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in the ‘gap’ (in that case). The evidence base does not determine robust and defensible boundaries, it merely indicates aspirational green corridors to separate adjoining SDLs, yet this is a fundamental element of the functioning of the Green Belt and the prevention of unrestricted sprawl. d) In relation to cells 26b and 26c, the JSP assessment elevates the parcels’ role by attributing an in-combination role with the adjoining cell (26a - Pucklechurch Ridge), which does in fact provide a defensive boundary and separation from Bristol. These three parcels together are considered to perform a ‘major contribution’ to the Green Belt Purpose 1 which we would agree with. However, it is cell 26a that performs the most strongly in relation to Purpose 1 and if cells 26b and 26c are considered independently and they are considered not to make a major contribution to Purpose 1 in the same way. 19. PBA’s Regulation 19 representations (paras 2.4.31-2.4.41) expand on these concerns relating to the JSP’s Green Belt assessment.

Question 2.2: In principle is it a justified and effective approach for the JSP to identify Strategic Development Locations (SDLs) in only broad and indicative terms and to leave to Local Plans the formal allocation of sites for the SDLS? 20. This approach not only relies upon Local Plans releasing sites, but also amending Green Belt boundaries where required. Such an approach means the JSP EiP cannot properly test the capacity and deliverability of these locations to achieve the housing delivery figures that are relied upon. 21. The advice in NPPF2012 para 83 is: “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.” 22. The release of Green Belt land therefore requires detailed analysis to secure justifiable defensible boundaries. Broad and indicative locations could prejudice the Local Plan process resulting in poorly conceived piecemeal Green Belt release. This process should be undertaken in tandem with the Local Plan evidence base. Whilst several LPAs have been undertaking a more detailed Green Belt release to justify the allocation of sites, others, such as South Gloucestershire will not have done so until after the JSP Hearings. 23. Furthermore, it raises a question about whether Local Plans would need to apply the NPPF2018 Green Belt test which have not been applied through this process and whether the outcomes would be different?

Question 2.3: The detailed justification of the criteria detailed in policies 7.1 – 7.12 will be considered in Matters 7.1 – 7.12. However, as a matter of principle, is the inclusion in the JSP of the strategic principles and infrastructure requirements set out in policies 7.1 – 7.12 justified and effective having regard to the statements in paragraph 66 (Chapter 4) of the JSP that they are the “starting point for detailed assessment through the local plans” and are “not exhaustive and will evolve as detailed assessment and masterplanning takes place”? 24. No, it is considered there is insufficient detail to be justified and effective. There is no certainty regarding the actual level of development that will be deliverable at each SDL as the suitability and deliverability of the SDLs has not yet been fully tested (as set out in IM’s Regulation 19 representations at Section B1, Appendix B). Therefore it is not possible to robustly ascertain the level of infrastructure need and deliverability. It is suggested that further detail is provided regarding the deliverability of the SDLs so that the necessary level of information can be provided regarding infrastructure delivery, such as detailed viability testing and more detailed development briefs. 25. Some locations are heavily reliant upon new infrastructure to attempt to introduce sustainability in unsustainable locations.

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26. For example, Banwell and Churchill are reliant on a new road bypass to accommodate the level of new development proposed. Locating two SDLs in an isolated area where a major new highway scheme is necessary is not conducive to sustainable development, and conflicts with the JSP’s vision and strategic priorities, and the principles that underpin the spatial strategy set out in paragraph 4.79 of WED009.

Question 2.4: The Councils have suggested modification to paragraph 66 (Chapter 4) of the JSP (Doc WED 002) to remove reference to the strategic principles 4 and infrastructure requirements being a “starting point” and to the potential for them to “evolve”, whilst making clear that they will be “supplemented by additional policy guidance as detailed assessment and masterplanning takes place”. In principle, would this modification provide for an effective approach in relation to the identification of the SDLs in the JSP and their anticipated formal allocation as sites for development in forthcoming Local Plans?

27. No, this appears to be the same approach by a different means. 28. Additional detail and clarity should be provided on both the SDL development yields and the necessary supporting infrastructure at this stage to ensure they are viable and deliverable. Matters relating to infrastructure need and deliverability should be tested at this stage to ensure the proposals are realistic, viable and deliverable. 29. There is a significant level of uncertainty around SDL development and infrastructure deliverability which would not be resolved through the introduction of additional guidance. SDL’s make up a significant portion of housing delivery in the spatial strategy, therefore their delivery is key to the success of the Plan. There should be clarity on these matters from the outset.

Question 2.5: Is the plan’s statement (paragraph 12, Chapter 4) that there are exceptional circumstances to justify the release of “certain locations” from the Green Belt supported by robust evidence, justified and consistent with national policy? [Note: specific impacts on the Green Belt will also be considered in Matter 7 under the relevant Strategic Development Locations].

30. IM agree that there are exceptional circumstances to release Green Belt land, but that they do not solely relate to those SDLs that are proposed to be removed. NPPF2012 is framed around the concept of sustainable development, which as it describes in paragraph 6, this is the document taken as a whole. Section 9 of the NPPF2012 recognises the importance of considering exceptional circumstances in the context of the wider selection of sustainability policies. Paragraph 83 and 84 of the NPPF2012 should be read together, specifically:

. Green Belt boundaries can be altered in exceptional circumstances as part of a plan review1. . When considering a review of Green Belt boundaries, account should be taken of the need to promote sustainable patterns of development, including considering the consequences for sustainable development of challenging it towards urban areas and villages inside the Green Belt as well as beyond the outer boundary.2

31. The JSP has sought to promote a strategy, wrongly in IM’s view, which seeks to avoid Green Belt development as far as possible (SA Scenario 1 (WED009), yet finds itself accepting that for sustainability reasons, locating development within the Green Belt at villages like Keynsham achieves a broader range of sustainable development objectives. IM agree that Bristol and Bath are the most sustainable locations and offer the best opportunities to reduce car-based travel and shorten journey lengths. Locating necessary development at or near to these centres, within the Green Belt is

1 NPPF2012, para 83 2 NPPF2012, para 84

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exceptionally justified. IM concludes that in respect of the remote SDLs at Banwell, Buckover and Churchill, this will undoubtedly increase car reliance with longer commuter trips, which will be unsustainable. The is leads to the exceptional circumstances for the identification of more sustainably located sites within the Green Belt, such as land at Pucklechurch.

32. To support IM’s conclusion, Appendix 1 demonstrates the sustainability credentials of its land at Pucklechurch West and through its critique of the Green Belt assessment process at Appendix 3 which shows both flaws in the approach taken by the JSP in its assessment.

Question 2.6: Does the plan provide sufficient clarity about the location and extent of the “certain locations” to be released from the Green Belt? Will it be clear to those preparing Local Plans the land for which the JSP indicates exceptional circumstances have been justified and the land for which it has not?

33. The JSP does not change the Green Belt and therefore does not define the land to be removed; this leaves uncertainty.

34. The plan does not provide sufficient clarity given that:

. There is no detailed GB assessment at district level; . It identifies broad locations for SDLs only, with no clarity on robust and defensible boundaries; and . There is no consideration of ‘cumulative effects’ of removal of multiple SDL areas from the Green Belt, for example, the in-combination effect of Yate and Coalpit Heath.

Question 2.7: Is the Councils’ proposed modification to the JSP (new paragraphs 68 and 69, Chapter 4, detailed in Doc WED 002) effective and consistent with national policy? Is the modification’s statement that “It will not be within the remit of Local Plans to review the in principle decision or to restate the exceptional circumstances to remove these locations from the Green Belt” justified, particularly in the light of the level of detail set out in the JSP on the location and extent of the “certain locations”?

35. As noted in PBA’s additional evidence representations at paragraph 2.1.6, the Green Belt exceptional circumstances should relate to the principle of releasing Green Belt land in sustainable locations (as per NPPF2012 para 84 which notes the need to consider sustainable patterns of development), and not just the five SDLs in the Green Belt. 36. This is tempered by the understanding of the effects that releasing Green Belt land would have on the purposes of designating the land in the first place. In the context of a plan that doesn’t identify specific boundaries for land to be released and only provides an indicative housing figure, it is difficult to understand how the selection of certain sites for release can be justified at this stage and implemented in the future. 37. We recognise that some work has been carried out relating to assessment of potential SDL areas, as per the requirements of NPPF2012 paragraph 82. However, this has not resulted in specific boundaries being drawn and it will not form part of the adopted JSP. Consequently, there is no obligation, in development plan terms, to be bound by this detail when it comes to determining areas of release at Local Plan stage. 38. The JSP does not make changes to the Green Belt for the above reasons. As the changes are being made at Local Plan level and it is bound by the tests in NPPF, the conclusion of whether the sites warrant exceptional circumstances must take place at that stage. Therefore the JSP cannot confirm that exceptional circumstances exist for each individual SDL, as only broad locations are identified. 39. Notwithstanding the above, there is no doubt that exceptional circumstances exist for some the SDLs that are in the Green Belt. Indeed, IM support the justification of exceptional circumstances for

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additional SDL sites, as a result of NPPF2012 para 84’s requirement to consider sustainable patterns of development.

40. This is explored further in PBA’s Additional Evidence representations (paragraphs 2.1.2-2.1.7). Question 2.8: Is it envisaged that Local Plans will propose additional alterations to the boundary of the Green Belt beyond those proposed in relation to the SDLs? If so, should the JSP set the strategic framework for such alterations and the alterations proposed in relation to the SDLs be considered as an integral part of that?

41. The impact of development on the Green Belt is a spatial matter and the JSP does not currently provide sufficient detail for specific areas to be released by the Local Plans. Consequently, it is not clear if the sites meet the criteria for removal. It is therefore envisaged that further work will be required by Local Plans. 42. A strategic framework, which defines the distribution of development to different locations could be a good way of achieving Green Belt release, given that: a) It is currently known at a high level that Green Belt release is necessary to deliver sustainable development; and b) The exact amount of land to be released is not currently known as the JSP only identifies broad areas relating to the SDLs. As such, the amount of development isn’t known.

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APPENDIX 1: PUCKLECHURCH WEST VISION DOCUMENT

This is enclosed as a separate document

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Pucklechurch West Vision Document

May 2019 The Proposal

The site presents an excellent opportunity to release approximately 85 hectares of land to deliver high quality sustainable housing, employment and green infrastructure that will help to meet the identified future needs of the West of England.

The approach for the site is to develop a landscape-led development of about 2,500 high quality new homes that complement the surrounding context. These homes are proposed to be supported by around 20 hectares of economic development to create a vibrant and balanced community.

This Vision Document has been prepared by The Environmental Dimension Partnership Ltd. (EDP) and PBA (part of Stantec) on behalf of IM Land, part of the IM Group.

IM Land is one of the UK’s leading land promoters, working across a range of sectors and rooted in the Midlands. IM Land are committed to securing high quality, long-term developments through a fair approach to business and the community.

EDP and PBA have extensive experience of planning, designing and delivering high quality, sustainable and environmentally sensitive regeneration projects across the UK.

edp3485_r009b Overview

As a result of growing demand for housing and employment space in the West of England, which cannot all be accommodated within existing urban areas or on brownfield land, this document explains why land at Pucklechurch West can deliver this growth in a sustainable manner.

This document:

• Identifies some of the locational benefits of this area;

• Highlights opportunities to shape sustainable growth on the edge of the Bristol conurbation;

• Confirms that the site is deliverable; and

• Confirms there are no environmental impediments to the creation of a comprehensive mixed-use development (including housing, employment and community uses).

It concludes that delivering housing and employment in a location that is already a focus for major jobs growth (Science Park/ Emersons Green) and new infrastructure (Metrobus and a potential M4 J18a) is a strong sustainability reason to locate some of the Joint Spatial Plan (JSP) housing and employment need at Pucklechurch West.

In this context, IM Land will set a fixed vision at Pucklechurch West and identify themes and principles upon which a future vision and set of objectives can be formulated in consultation with stakeholders.

It is intended that these themes below, will eventually be refined through discussion and from this, a holistic, detailed vision can be established.

The vision themes are:

• Balanced housing and jobs growth at North East Bristol;

• A healthy community;

• Delivery of affordable homes;

• Making the most of access to existing public transport, cycle and pedestrian facilities and where appropriate, their improvement;

• Using the landscape to maintain the separate identities of Emersons Green and Pucklechurch;

• Responding to community infrastructure needs arising from the proposals; and

• Responding to topographical, ecological, historical and other environmental aspects of the site and its immediate environment.

1 Introduction

Pucklechurch and its context Is there a need for development? Pucklechurch is a sustainable settlement in South Gloucestershire, It is acknowledged that land around Pucklechurch sits within the Bristol- approximately 2km east of the greater Bristol conurbation. Bath Green Belt, a designation that has five purposes. The Government has identified that the UK has a “broken housing market.” This can be resolved by building new houses where • To check unrestricted sprawl of large built up areas; The communities of Lyde Green, Emersons they are needed most, and where they are within easy access Green and Harry Stoke now occupy land up • To prevent neighbouring towns merging; of places of work, community facilities and public transport links. This will result in delivering sustainable development – an to the edge of the M4 and Outer Ring Road. • To safeguard the countryside from encroachment; overarching requirement of national planning policy. These communities benefit from recent • To preserve the special character of historic towns; and major infrastructure and community services • To assist urban regeneration and the recycling of derelict land. The West of England JSP indicates a need for about 105,000 homes and 82,500 new jobs to sustain economic growth in this part of the South investment. Some land within Green Belt can perform strongly against one or more of West, in order to maintain the competitive business advantage that the the five purposes, whereas other land perform does not. The site does sub-region enjoys over other parts of the UK. This is a significant amount Pucklechurch is the nearest settlement with existing facilities, services not perform a significant Green Belt function, however, as a greenfield of housing and employment but is not enough to meet the Government’s and a growing employment base. It is a sustainable settlement set within location, it is recognised as being part of the wider countryside. Mindful minimum National Housing Requirement set for this area of 115,000 a wider, highly sustainable part of the West of England. It benefits from of this, proposals for the site would seek to respond to the character of homes. This falls short of other forecasts which suggest true need is more being located within bus and cycle distance of regional scale economic the landscape; this would include retaining areas of countryside and open likely to be 140,000 dwellings. investment at the Bristol and Bath Science Park (and 9,000 new jobs). space. In this context, Green Belt sites should be assessed fully, rather than just considering sites beyond the Green Belt, which in many cases The National Housing Requirement is now written into national policy and Pucklechurch has a current population of approximately 3,000 residents. may not be in sustainable locations. would result in sites for 10,000 more houses being needed here. This It benefits from good provision of popular sports clubs and community alone is a significant reason supporting the need for the allocation of land societies, communal spaces and a safe environment. It has a primary at Pucklechurch West. school, shop, post office and social venues including a pub. Although weekly convenience and comparisons goods shopping trends are rapidly This document goes on to explain in the context of need, why land at changing to an online environment, Pucklechurch is close to supermarket Pucklechurch represents a sustainable and co-ordinated solution to and comparison goods shops at Emersons Green. Sport and Secondary addressing and meeting housing need in alignment with improvements to School provision is similarly available close by at Mangotsfield. existing and providing new infrastructure. This avoids the need to locate development in unsustainable, remote SDL locations beyond the outer edge of the Green Belt in accordance with National Policy.

2 Introduction

Initial consideration of opportunities & benefits

Pucklechurch has numerous positive characteristics, but there are opportunities that development on the western side of the settlement could bring in order to benefit the local community and support growth in a successful, self-sustaining way:

• Helping to meet local housing needs generated within the West of England, especially the provision of a range of homes that provide different affordable routes into the local housing market;

• Helping to provide for a range of accommodation for different household profiles, whether first time home owners, growing families or elderly and less able;

• Improving connections with other local settlements such as Yate, Emersons, Green Lyde Green and Harry Stoke by public transport/cycling/walking, whilst making the best use of existing infrastructure (such as local Sustrans cycle paths to the Bristol and Bath Science Park and connections to the nearby Metrobus route);

• An opportunity to re-route through-traffic from Yate away from the intersection of Westerleigh Road, Abson Road and Shortswood Road; thereby enabling environmental improvements for pedestrians and cyclists;

• The provision of new community facilities to complement those already provided.;

• An opportunity to support local business growth and investment beyond that provided by Pucklechurch Trading Estate which, generally has limited spare capacity; and

• An opportunity to provide greater access to local open green space supported by a net gain in ecological bio diversity.

Figure 1. Wider Contextual Plan

3 A Sustainable Location

The site has exceptional access to a wide range of Journey times and distances to the major Bristol employment areas (listed below) are significantly shorter than travel from locations beyond the Green nearby transport modes and routes, all of which Belt:

could be joined up to Pucklechurch. These • Emerald Business Park – c.3km (10min cycle/5min drive)

include: • Bristol and Bath Science Park - c.3km (10min cycle/5min drive) • Metrobus (and the potential extension to Yate); • Lyde Green - c.2km (less than 10min cycle/less than 5min drive) • Bristol- Bath Cycle Path and Sustrans routes adjacent to the site; • University of West of England - c.8km (30 min cycle/10-15min drive)

• Park and Ride (Lyde Green); • Bristol Business Park - c.8km (30 min cycle/10-15min drive)

• M32, M4 and A4174 (Bristol ring road); • Bristol Parkway Business Park - c.9km (40min cycle/10-15min drive)

• Bristol Parkway Station (north Bristol) and Temple Meads • Abbey Wood MoD - c.9km (40min cycle/10-15min drive) (central); and • Bristol City Centre - c.10km (40min cycle /20-30min drive) • Potential new M4 J18a. Many of these are the focus for employment growth and expansion supported by the Local Enterprise Partnership (LEP). Reduced journey distances and choice of sustainable travel modes has the potential to improve the Bristol City Air Quality Management Zone.

Although Pucklechurch is a standalone settlement, it is exceptionally well In this context locating development at Pucklechurch West represents a connected to central Bristol, the M4/M5/M32 strategic motorway network, real opportunity to change travel patterns and modes. and the national rail network at Bristol Parkway station. It is also well connected via the Bristol- Bath cycle path providing a dedicated, off road route to the centre of the City.

Strategic scale development at the site is not dependent upon major new highways infrastructure,but could help to deliver it and unlock the economic potential of this area of the North-East Bristol fringe. Figure 2. Extract from Bristol LEP Map

A business case is currently being prepared for a new junction on the M4 (J18a) which would link the motorway with the ring road (A4174). Land to the east of the site is one of two options being considered for the new junction – known as the ‘eastern option’. The ‘western option’ would access directly into the Bristol and Bath Science Park and is currently preferred by South Gloucestershire Council. The ‘eastern option’, which provides better flexibility and network resilience in the future, is about £400m less expensive and remains part of the business case until 2022. Both options are compatible with Pucklechurch West and the development options beginning to be considered.

4 A SustainableLocal Opportunities Location

Science Park

School

Doctors Surgery

Public House

Place of Worship

Convenience Shop

Post Office

Community Building

H NHS Treatment Centre

Major Employers

PR Lyde Green Park & Ride

Public Right of Way (Footpath)

Public Right of Way (Promoted)

Metrobus Route

Sustrans Cycleway Route 410

Sustrans Cycleway Route 16

Spine Road

Sites with extent consent

Potential junction 18a locations being considered

Figure 3. Local Contextual Plan 0 5 min walk 0 5 minute cycle 400m 1400m

5 Aligning with the Joint Spatial Plan Vision

South Gloucestershire is one of four West of England councils proposing to deliver 105,000 new homes Symbol Effect in the region, as set out in their emerging JSP. This means there will be high levels of housing growth ++ Significant positive effect across the region in the next 20 years. This section sets out how development at West Pucklechurch (incapable of further enhancement) likely ++/- Mixed significant positive and minor negative effect likely aligns with the vision, objectives and sustainability criteria of the JSP and would be a sustainable + Minor positive effect (capable of enhancement) likely location for new housing and community facilities. overall (includes minor positive effect mixed with uncertain (includes +/?, ?/+, 0/+) or negligible effects) Mixed minor or significant effects likely JSP vision: +/-, ++/- -, -/+ - Minor negative effect (capable of mitigation) likely overall “By 2036 the WoE will be one of Europe’s fastest growing and most prosperous city regions with the gap between disadvantaged (includes -/?, ?/-) (includes minor negative effect mixed with uncertain effects) and other communities closing and a rising quality of life for all. The rich and diverse environmental character will be integral - -/+ Mixed significant negative and minor positive effects likely to health and economic prosperity. Patterns of development and transport will facilitate healthy and sustainable lifestyles. Significant negative (incapable of further mitigation) effect - likely (includes significant negative effect mixed with minor (includes 0/- -, -/- -) Provision of a range of housing types, will be of high quality and more affordable. Existing and new communities will be well negative or negligible effects) 0, 0/? Negligible effect likely or mixed with uncertainty integrated, attractive and desirable places and supported by the necessary infrastructure. New development will be designed ? Likey effect uncertain to be resilient to, and reduce the impacts of climate change”.

SP1 Meet the sub-region’s identified housing needs in a sustainable way, Scheme Characteristics aligned with JSP vision SP1 SP2 SP3 SP4 including substantially increasing affordable housing supply. SP2 Pursuing inclusive economic growth by accommodating objectives of the Provision of high-quality market and affordable housing to meet the needs of all groups of the community. LEP’s Strategic Economic Plan: Reputable developers/architects/consultants will be used during the development process to ensure delivery of a high-quality development that - Promote growth of existing employment centres such as such as the Enterprise respects the existing local character, context and environment. Zones and Areas;and - Ensure more inclusive life chances for all and improve accessibility to jobs. Future development proposals would focus on community needs and well-being, putting the resident/occupant first to deliver a mix of SP3 Deliver a spatial strategy which: complementary uses (housing, employment, community/leisure), and implementing best practice design principles. - Focuses on primary centres of Bristol, Bath and Weston-super-Mare, and Site location within walking/cycling distance of local facilities and employment opportunities. recognises the complementary roles of market towns to achieve sustainable growth; Potential improvements to public transport to improve connectivity to wider facilities. This should encourage healthy lifestyles and reduce car use, helping to improve the environment. - Ensures that new development is properly aligned with infrastructure and maximises opportunities for sustainable and active travel; Provision of public open space, sports/exercise facilities, and access to footpaths and cycleways encourage healthy lifestyles and enhance - Through a place-making approach, promotes places of density and scale biodiversity. with a range of facilities and which encourages healthy lifestyles and cultural wellbeing;and

Development of this scale would bring new infrastructure (such as public transport, community facilities, and biodiversity improvements) to the - Integrates high quality, mulit-functional green infrastructure. Reduces area, improving sustainable connections with both local and more distant employment opportunities and facilities. greenhouse gas emissions and ensure resilience to the impacts of climate change. SP4 To protect and enhance the sub region’s diverse and high quality natural, Routes through the site provide an opportunity to alleviate road traffic passing through Pucklechurch, improving air quality and noise pollution, as built and historic environment and secure a net gain in biodiversity. well as the overall quality of environment for local residents. To prioritise development on brownfield locations, optimise densities and retain the overall function of the Bristol and Bath Green Belt.

6 Aligning with the Joint Spatial Plan Vision

JSP Strategic Priority Sustainability Assessment Criteria Score Comment

1 Meet the sub-region’s identified housing needs in a 2a - Deliver a suitable quantum of high quality housing for the West of The site has potential to deliver c.2,500 homes in a sustainable location to help meet the identified need. sustainable way, including substantially increasing England sub-region. ++ Any future development will be able to deliver an appropriate mix of both open market and affordable housing to meet the needs of the area. affordable housing supply. 2b - Deliver a suitable mix of high-quality housing types and tenures The site performs very well against the relevant Sustainable Assessment (SA) criteria and would successfully deliver Strategic Priority 1. (including affordable housing) for all parts of society within the West of ++ England sub-region. 2 Pursuing inclusive economic growth by 2f - Reduce poverty and income inequality, and improve the life chances of Future development will provide a land for a variety of employment types and sizes, particularly towards north of site. accommodating objectives of the LEP’s Strategic those living in areas of concentrated disadvantage. 0 The site has the logistical benefits of being close to the M4, but is closer to the edge of Bristol rather than an extension of a town which is Economic Plan: 3a - Deliver a reasonable quantum of employment floorspace/land and reflectedin the scoring. - promote growth of existing employment centres increase access to work opportunities for all parts of society within the + The site is c.3km from Bristol and Bath Science Park at Emersons Green Enterprise Zone with good cycle access (c.10 minutes). A future such as such as the Enterprise Zones and Areas; West of England sub-region. development would seek to improve bus routes in the area as potential mitigation. This would improve the site’s sustainability credentials. - ensure more inclusive life chances for all and 3b - Achieve reasonable access to major employment areas Major The site is not close to an area identified in the 25% most deprived areas in England. This is consistent with all the identified Strategic improve accessibility to jobs. Employment sites: ++/- Development Locations (SDL) and the scoring reflects this. - Enterprise Zones; and The site performs well in this regard and would be successful in improving accessibility to employment and delivering economic growth, - Locally designated key employment areas. consistent with Strategic Priority 2. 3 Deliver a spatial strategy which: 1b - Minimise impacts on air quality and locate sensitive development The site is not in an Air Quality Management Area (AQMA) but the northern part is close to the M4. Trees and other vegetation surrounding the away from areas of poor air quality. + site help to mitigate this. - focuses on primary centres of Bristol, Bath and Weston-super-Mare, and recognises the 1c/2c/2d - Achieve reasonable access to healthcare, community and The site is near to the following social/community facilities: complementary roles of market towns to achieve + education facilities (Doctors, Opticians, Pharmacies, Dentists, Hospitals, • GP surgery (Pucklechurch, c.600m) sustainable growth; post office, meeting/activity venues, primary/secondary schools). • Hospital (Cossham Hospital, c.5km) - ensures that new development is properly 2e - Achieve reasonable access to town centre services and facilities • Dentist, optician, pharmacy (Emersons Green, c.2km) aligned with infrastructure and maximises (Designated City, Town and District Centres).. - • Youth facilities at Pucklechuch sports/social club (Pucklechurch c.600m), opportunities for sustainable and active travel; • Post Office (Pucklechurch, c.600m), 5a - Achieve reasonable access to sustainable transportation (rail station, • Community centre (Pucklechurch, c.800m). - through a place-making approach, promotes +/- bus stops, cycle paths, footways) • Primary school (Pucklechurch Primary, c.800m) places of density and scale with a range of • Secondary school (Mangotsfield School, c.2km) facilities and which encourages healthy lifestyles 5b - Reduce non-renewable energy consumption and ‘greenhouse’ 0 and cultural wellbeing;and emissions, and provide opportunities to link into existing heat networks. The site is within c.10km of Bristol City Centre, and c.2km of Emersons Green Town Centre. There is a bus service part of the journey to Emersons Green,but some walking would be required. The entire journey would take c.10 minutes to cycle. - integrates high quality, multifunctional green infrastructure. Reduces greenhouse gas The site benefits from good access to footpaths/cycle paths (within 400m) and a bus stop (within 400m), however this is only served by two bus emissions and ensure resilience to the impacts routes. The nearest rail station (Bristol Parkway is c.8km away). of climate change. A future development could provide additional primary education and community facilities, as well as improvements to existing bus routes. This is potential mitigation and would improve the site’s sustainability credentials. Future development is likely to consume non-renewable energy, but this is consistent across all sites and the scoring reflects this. Overall the site performs well against criteria relating to sustainability of location and access to facilities.Future development in this location would therefore successfully deliver Strategic Priority 3. 4 To protect and enhance the sub region’s diverse 4a/4b - Minimise impact on, and where appropriate enhance the historic There are listed structures and a (Scheduled monument) SM and two conservation areas in the vicinity of the site, and it is close to an Site and high quality natural, built and historic environment, heritage assets and their settings, and habitats and species ? of Nature Conservation Interest (SNCI). The design and location of future development will respect these assets, and from an ecological environment and secure a net gain in biodiversity. (taking account of climate change). perspective seek to deliver an overall net gain in biodiversity. To prioritise development on brownfield locations, 4c - Minimise impact on and where appropriate enhance valued The site is not the Cotswolds Area of Outstanding Natural Beauty (AONB) boundary or setting (4km away). optimise densities and retain the overall function landscapes. - The site is greenfield land and has the same scoring as all other SDLs. The spatial strategy acknowledges that greenfield development is of the Bristol and Bath Green Belt. 4d - Promote the conservation and wise use of land, maximising the re-use necessary to meet the identified housing need. of previously developed land, - The site has an agricultural land classification value of grade 3 or lower; it is therefore of low agricultural value. 4e - Minimise the loss of productive land, especially best and most The site is in Flood Zone 1 (lowest flood risk). Future development would be designed around the defined reservoir breach zones. The site is not versatile agricultural land, + in or near to a groundwater protection zone and this scoring is consistent with other SDLs. 4f - Minimise vulnerability to tidal / fluvial flooding (taking account of The scores show an overall good performance against the SA criteria. climate change), without increasing flood risk elsewhere. ++ Any potential adverse impacts could be addressed and improved through the masterplanning/design process. The site is in the Green 4g - Minimise vulnerability to surface water flooding and other sources of Belt, however development would relate well to Pucklechurch and the overall Green Belt function would be retained. Delivering sustainable flooding, without increasing flood risk elsewhere. +/- development is the JSPs main reason for Green Belt land release; development of the site would align with this and successfully deliver Strategic 4h - Minimise harm to, and where possible improve, water quality and Priority 4. availability. 0

7 Site Evaluation

To inform the on-going Transport promotion of the site, a suite The site is well located to align with existing and new transport infrastructure, which offers a range of of technical studies have been alternative travel options and short travel distances to employment, city centre and other locations undertaken testing capacity and

deliverability. The summaries The principle access points for the site would from the B4465 to the north- east and south of the site, connected by a new through-route. Initial work opposite highlight the key has proven that these access points will accommodate the envisaged level technical considerations and of growth. The new through route would provide an alternative to travelling through the centre of Pucklechurch, reducing traffic going through the village.

opportunities which would Development would be based on walkable neighbourhood principles, connecting into existing footpaths and cyclepaths around the site. These be influential in future design provide easy pedestrian and cycle access towards Bristol city centre, proposals. Emersons Green Enterprise Zone and Pucklechurch. The site is within cycling distance of public transport routes at Lyde Green Park and Ride and the Metrobus at Emersons Green.

The site is currently served by two bus routes. Future development would provide the opportunity for the metrobus route to be extended out to Pucklechurch, further improving access to Bristol city centre.

Figure 4. TransportPlan The Bristol Science Park (less than a 10 minute cycle from the site)

8 Site Evaluation

Highways It is recognised that the highway strategy for Pucklechurch West should seek to ease or reduce existing through traffic movements around the Westerleigh Road/Shortwood Road and Abson Road junction. Such a strategy could create a link road between the B4465, south of the site, exiting north of Pucklechurch centre on the Westerleigh Road.

Initial analysis illustrates that access to the south could be taken from the Access to the east of the site would be taken from the B4465 Westerleigh B4465, which is a single carriageway for most of its length with a speed Road which is a single carriageway, and has a speed limit of 40mph before limit of 40mph. becoming 30mph on the approach to Pucklechurch, north of Castle Road. The carriageway remains flat along the site boundary length. There is a A 3m foot and cycle way is provided to the south of the carriageway. The large verge on the western side of the B4465 with established hedges of footway is of good quality and looks to have been recently upgraded. To both sides of the carriageway. the east of the B4465/Shortwood Hill junction, a footway is also provided to the north of the carriageway, approximately 1.45m in width however it is There is no indication at this stage of significant capacity constraints on the very intermittent along the stretch of road to the Siston Lane junction. The immediate wider strategic network, especially in the context of the range of foot and cycleway to the south of the carriageway is discontinued at the travel choices (bus, cycle pedestrian, rail). B4465/Siston Lane junction.

Figure 5. Highways Plan Westerleigh Road (south of the site) Westerleigh Road (through Pucklechurch)

9 Hydrology Utilities The site is not at risk of flooding and there are no The site is crossed by a limited number of underground Groundwater source protection zones nearby. mains that can be readily integrated with development.

The site is located in an area that is not at risk of being flooded (Flood Relative to the scale of the site, there are few utilities crossing it. Zone 1). The utilities which are present are predominantly located in the southern A small stream and area of marshland with seasonal ponds are located portion of the site and can be readily integrated with development with in the northern and north-eastern areas of the site. These features will be minimal need for diversion. managed appropriately at detailed design stage.

A reservoir is located towards the south of the site. The reservoir flood breach zones will be respected and development will be carried out in collaboration with the relevant flood authorities. There has been no breach since construction of the reservoir.

The reservoir itself does not form part of the development area and would be retained within the context of an emerging development masterplan.

Earth mounding and established planting around the reservoir Figure 6. Flooding and Drainage Plan Figure 7. Existing Utilities Plan

10 Site Evaluation

Ecology Heritage Investigations have identified no significant ecological Investigations have confirmed there are no in principle constraints to the development of the site. heritage constraints to deliverability.

The site comprises approximately 40 field parcels which constitute a mix of A desk-based assessment and walkover study of the site identified a number large arable fields and smaller pastoral field. The majority of the site is under of localised heritage factors, but no-in principle heritage constraints to arable production but with some improved and semi-improved grassland and development. an area of marshy grassland in the lowest part of the site to the north. Pucklechurch Conservation Area (CA) and the numerous listed buildings The field boundaries principally comprise hedgerows, some of which are which sit within it, including the Grade I listed St. Thomas a Becket Church, well-treed and are variably managed. Woodland habitats comprise a young adjoins the site with a single minor intrustion beyond the site boundary. The deciduous plantation and a series of planted tree belts. Other habitats/ CA would be addressed to conserve its special interest, for example through land uses within the site include a small remnant orchard to the north east retention of generous provisions of green space within it and along its edges. of Parkfield and a further remnant orchard located just outside the eastern From an urban design perspective, opportunities to appreciate historic- boundary of the site, north of Kings Lane. assets, such as retaining sight lines to the church - will also be exploited to aid legibility and create visual and historic connections with the new Key principles for the safeguarding of ecological features include retention of community.i na ecologically beneficial habitats, such as woodland and waterbodies, creating a meaningful green infrastructure network and provision of appropriate Bowl Barrowiin lan Scheduled Monument, located in the south of the site and public open spaces to protect retained habitats in order to achive an overall currentlyiin in an overgrown state, has been identified as requiring retention, net gain in biodiversity. but alsoiin presenting a the opportunity to improve its management and

opportunitiesiin w for its appreciation by including it within open space.

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miim aal alan IM Properties Plc

Land West of Pucklechurch Figure 8. Ecological Constraints Plan Figure 9. Heritage Assets Plan Grade I listed St. Thomas a Becket Church

5000 11

0 00 400 00 00 000 m

IM Properties Plc

Land West of Pucklechurch

5000

0 00 400 00 00 000 m Agricultural Land Classification Topography Landscape Character The site would not result in the development of the Within the site the landscape is gently undulating The site exhibits a series of clear landscape best and most versatile agricultural land as it is with more pronounced changes in level to the west characters which identify with the immediate classified as grade 3 or lower. and south. context and would help to shape future proposals.

The landscape character has a number of settlement and perceptual Developing the site would not result in the development of best and most The site lies on a broad plateau of Oolite Limestone which has eroded over influences. These combine with the physical site features to form four versatile agricultural land. time to form the distinctive ‘Pucklechurch’ scarp to the west of the site. primary character areas: The site is classified by DEFRA as being 3b-moderate in terms of The site’s highest point in the south east (by the underground reservoir) is Northern Meadows – the smaller field parcels; strong hedgerow agricultural quality and is not protected from being developed. approximately 122m above Ordnance Datum (aOD) from where it slopes boundaries; lower lying and marshy at times; influenced by the sound of gently to the northern boundary with the M4 for around 1400m to 99m traffic on the M4; aOD (a gradient of less than 1:20). Open, Arable Farmland – very large field parcels; open in nature Very Good The site is topographically comparable with that of Pucklechurch to the with distant as well as middle distance views; east. From the high point adjacent to the reservoir there is a marked slope Good to moderate Pucklechurch Edge – largely enclosed small-scale pasture; trees over 300m to the site’s southern boundary with the B4465, after which the and copses break up the settlement edge; and Poor land continues to slope gently southwards. Land predominantly in urban use Southern Slopes – greatest number of urban influences; including the artificial mounding and infrastructure of the reservoir; a travellers’ site; and ‘plantation’ woodland.

Extract from NE 1:250 000 Series ALC Mapping Figure 10. Topography Plan

12 Site Evaluation

Green Belt The site has opportunity to define clearly, using physical features that are readily recognisable, permanent Green Belt Boundaries.

The site currently contains some built development which compromises its openness to some degree. Broadly speaking the site is comprised of a Emerald Park fragmented mosaic of agricultural, residential and settlement fringe land uses with clear defensible boundaries on all sides. Although development of the site would bring the settlement of Pucklechurch closer to Bristol, the Pucklechurch Ridge with it’s strongly wooded character prevents any actual Bristol Science Park DPD Distribution Centre or perceived merging or coalescence with the urban edge of Bristol. The site is not proximate or visually linked to the historic core of a town.

Therefore, it is considered that the site could reasonably be removed from the Green Belt and developed in accordance with the principles in the Concept Masterplan without harm to the integrity of the Green Belt overall.

Lyde Green as seen from Coxgrove Hill on the edge of the Pucklechurch Scarp Figure 11. Green Belt Boundary (view from the Community Forest Path west of the site)

13 Arboriculture Public Rights of Way Air Quality The character of the site is partly derived from The site is bisected by numerous public footpaths There is no air quality management area in the vicinity existing vegetation which helps to enclose much of which connect the site with surrounding areas. of the site and no local air quality issues. the landscape.

A number of the footpaths connect to the Community Forest Path The site is not within an Air Quality Management Area. The most distinctive woodland features within the site, include the tree- promoted route, which heads west from the site boundary down through lined Kings Lane which extends west from Pucklechurch to the centre It is recognised that central Bristol and parts of the main arterial roads are the woodland on the escarpment to connect to the Bristol and Bath of the site to join with a linear field boundary copse of mixed native within an AQMA. The ability to support a multi-modal transport approach Railway Path. broadleaves. Historic maps indicate that this was also once an extension of at Pucklechurch would help reduce car use on these routes, helping to the tree lined Kings Lane but the route has become disused and woodland Whilst much of the site is well served by the Public Rights of Way (PRoW) improve air quality in and around central Bristol. vegetation has subsequently extended to ‘fill the gap’ creating a wider Network, there is an opportunity for the creation of additional routes within woodland belt. the southern slope area, where users are afforded a long-distance view southward to the Cotswold AONB and Dundry. A young deciduous plantation woodland is also present in the southern portion of the site, whilst a coniferous copse has been planted on the western slopes of the reservoir. Planted tree belts also form a distinct visual barrier between the site and the M4 motorway along the northern boundary. There are no statutory designations relating to any of the existing trees and therefore no constraint to development is anticipated.

Figure 12. Arboriculture Plan Figure 13. Public Rights of Way Kings Lane

14 Site Evaluation

Parkfield Rank Historic terraced form with open PARKFIELD front aspect

Placemaking Proposals will be designed to respect the character Pucklechurch (North) of the local area and sensitively respond to the Very low density, verdant, often amenity of existing communities. open, historic boundaries, exhibiting a mixture of rear and side built elevations

The site lies between Pucklechurch and the linear hamlet of Parkfield. Both settlements have a series of unique characteristics which help to create a defined local identity broadly consistent with the wider South Historic Core Gloucestershire vernacular.

The figure opposite illustrates at a very high-level, some of the key placemaking considerations which would form part of a design process to develop a vision and character for the whole Pucklechurch West community. This holistic design approach would ensure all elements which Active recreational combine to create healthy, successful places are jointly considered. spaces

Kings Lane Historic ‘green street’ connection to the centre of the village

Network of green streets Pucklechurch (South) Modern enclosed rear gardens with uniform building lines

PUCKLECHURCH

Prison and Trading Estate

Figure 14. Initial Design Observations

15 The Opportunity

A cohesive and sustainable community embedded within a network of healthy green spaces .Set within the established woodlands of Pucklechurch, the new community will join seamlessly with the existing village, knitted together by an expansive and varied landscape.

IM Land is committed to ensuring that development at Pucklechurch West would both create meaningful local benefit and also build on the ideas, innovation and enthusiasm of the south-west region, through a collaborative and inclusive design process.

Designed as a walkable neighbourhood which promotes healthy living and active travel, development proposals would build on the rich built and landscape heritage of the site and locale to deliver a modern community that is well-connected to local employers and community resources.

Initiatives for new technologies will be considered on site and naturally-managed landscapes will provide a range of ecosystem services at the heart of the site design philosophy.

New employment areas, community facilities and public open spaces will allow Pucklechurch West to grow and evolve, meeting current local needs and supporting and retaining future generations within the community.

The historic village core will be sensitively integrated into the wider scheme, retaining its rural character and distinct identity. At these direct interfaces the layout, architectural form and materials will be rooted in the local vernacular and include generous communal landscapes.

16 The Opportunity

Potential Motorway Services

Employment Opportunities

Community Resources

Retail Opportunities

Primary Education

Sustainable Connections

Walking & Cycling Routes

Community Gardens

Village Green

Formal Sports

Active Woodlands

Children’s Play

Figure 15. Vision Sketch Plan

17 Development Benefits

2,500 3,500

Approximately 2,500 new homes Employment opportunities and Creation of significant new areas of Potential to deliver a new junction set within a network of functional potential for up to 3,500 of new jobs accessible open space and motorway services on the M4 public open space and pedestrian The site is well positioned to offer a range of The landscape features and context of the site present Land West of Pucklechurch has the potential to employment opportunities which compliment the an exciting opportunity to create a significant resource help deliver a new junction on the M4. Development and cycle routes employers already within the wider region. New to the benefit of both the local community and the proposals have been tested in both scenarios ,with New homes would improve accessibility to first time strategic highway connections to the A4174 and wider region. Harnessing these opportunities could or without the junction ,and are feasible in both buyers and increase the range of housing types, potentially the M4, plus delivery of direct and deliver a series of connected green spaces of varying instances. tensures and sizes in the locality, while new open accessible pedestrian and cycle connections into character and function. spaces would provide a range of activities, habitats the established surrounding network, also serve to and functions. reinforce the sustainable and accessible site location.

18 DevelopmentThe Opportunities Benefits

Reduce traffic congestion within Integrated blue-green Sustainable Connections Community Gardens Pucklechurch infrastructure New cycle paths would improve connections for Edible landscapes, community growing areas, Pucklechurch to the wider area. A greater number of allotments and orchards could all form part of the A new spine road through the site will provide direct A core objective of the landscape structure proposed residents would be served by more frequent public landscape areas which would link the new and existing and convenient access to the A4174 from Westerleigh as part of the new community, would be to ensure a transport services to key destinations such as central communities. Road to the north. This route would discourage traffic betterment of the current flood zones associated with Bristol, Emersons Green and Yate. from passing directly through the existing village the existing reservoir and minor watercourses on site. Such uses play an important role in building helping to improve air quality and to alleviate current Ground modelling and attenuation techniques would Parkfield Road has the potential to create a new communities and could provide an appropriate congestion issues. seek to improve flood defences in the unlikely event pedestrian priority spine to the new community, linking agricultural context to historic structures on the edge of a reservoir breach and create with it, an interesting existing facilities in Pucklechurch to Coxgrove Hill, the of Pucklechurch. and unique landscape. Bristol-Bath cycle track and thereon to key employers, community facilities and the metrobus.

h g i e l r e t s d e a W o R M4

PARKFIEL D

PUCKLECHURC H

19 Deliverability

The key design influences section of this document sets out “Bath and North-East Somerset Council worked with IM Land and their design team to respond that the site is deliverable from a technical perspective. to the opportunity at MoD Ensleigh and to help shape their proposals to deliver a significant development in a very sensitive location. The success of the scheme demonstrates the benefits of a shared vision for the site and its The site is being promoted as a comprehensive development scheme; a phased approach will be setting as well as IM’s early engagement with a progressed given the size of the scale of the site. Delivery of housing on will be phased in alignment range of stakeholders including the council. with new transport and community infrastructure to ensure the increase in population could be successfully accommodated. Phases would be deliverable in their own right, supported by the necessary The use of a planning performance agreement infrastructure, and would represent a logical progression of development. enabled the council to commit appropriate resources to meet IM’s programme and the Construction of the development could also be phased over different parts of the JSP Plan period to help delivery of a number of key policy objectives maintain a consistent housing supply for South Gloucestershire. including affordable homes and critical social To maintain a successful balance between housing growth and local employment growth, delivery of infrastructure to meet current and future needs.” housing could be aligned with delivery of future elements of the Bristol & Bath Science Park, together with Mark Reynolds local employment space on the site itself. Group Manager, Bath and North East Somerset Council

“We worked as a team with IM Land in complex planning negotiations for the main Ensleigh site and for the adjoining land, known as The Chill. IM Land also successfully let the contract and delivered the demolition and remediation of the site as part of the infrastructure works. IM Land had a strong understanding of the commercial issues for a house builder and how to deal with them efficiently.” Andrew Driscoll

Senior Land Director, Bloor Homes South West

20 Deliverability

New Homes at Ensleigh, Bath (former MoD site) delivered in partnership by IM Land

21 The Environmental Dimension Partnership Tithe Barn, Barnsley Park Estate, Barnsley, Cirencester, Gloucestershire GL7 5EG t 01285 740427 e [email protected] w www.edp-uk.co.uk HEARING STATEMENT

APPENDIX 2: DOCUMENT SD9G SUSTAINABILITY COMPARISONS

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HEARING STATEMENT

Page 10 of 12

NSC BA1 + + + ++ ++ + +/- - 0 + ? ? ?/- 0/------++ +/- ? +/- 0 Backwell BA2 + + + ++ ++ + ++ - 0 + ? ? ?/- 0/------+/- +/- ? +/- 0

NSC BN1 + + + ++ ++ + +/-- - 0 + + ? ?/------+/- +/- ?/- +/- 0 Banwell BN2 + + + ++ ++ + +/-- - 0 + + ? ?/- -- -- ?/+ +/- +/- ?/- +/- 0 BN3 +/- + + ++ ++ - -- - 0 + + 0 ?/- 0/-- -- ?/- ++ +/- ?/- +/- 0

NSC CH1 +/- + + ++ ++ +/- +/-- - 0 + 0 0 ?/------++ +/- 0 +/- 0 Churchill CH2 +/- + + ++ ++ + ++ -- 0 + 0 0 0 -- -- ?/- ++ +/- ?/- +/? 0 CH3 +/- + + ++ ++ - +/-- -- 0 + 0 - ?/- 0/------++ +/- ?/- +/? 0

NSC CO1 + + + ++ ++ +/- -- - 0 + 0 ? ?/- 0/-- -- - +/- +/- 0 +/- 0 Congresbury CO2 + + + ++ ++ +/- -- - 0 + 0 0 ?/- -- -- +/- +/- +/- 0 +/- 0

NSC EA1 - - + ++ ++ + -- - 0 + - ? ? +/- -- -- +/- +/- 0 ?/+ ? Easton-in- EA2 - + + ++ ++ +/- +/- - 0 + - - ? 0/------+/- +/- ? + ? Gordano

NSC LA1 + + + ++ ++ +/- +/-- - 0 + + ? ?/- ++/- -- ?/- +/- +/- ? +/- ? Long Ashton - LA2 + + + ++ ++ +/- ++ +/- 0 + ++ ? ?/- +/-- -- ? +/- +/- 0 +/- ?

NSC YA1 + + + ++ ++ + +/-- - 0 ?/- ? ? ?/- -- -- ?/- ? +/- ? -- 0 Yatton - YA2 + + + ++ ++ - +/-- - 0 + ? ? ?/- -/------+/- +/- ? -- 0 YA3 + + + ++ ++ + +/-- - 0 + ? ? ?/- 0/-- -- ?/- +/- +/- ?/- -- 0 -

SGC AH1 + - - ++ ++ - -/-- - 0 + + ? 0/? -- -- ? ++ +/- 0 +/- ? Almondsbury / AH2 + - + ++ ++ + -/-- - 0 + + ? 0 - -- ? ++ +/- 0 +/- ? Hortham AH3 + - + ++ ++ + ++ - 0 + + ? 0/? - -- ?/- ++ +/- 0 +/- ? AH4 + - + ++ ++ + -/-- - 0 + + ? ? -- -- ?/- ++ +/- 0 +/- ?

SGC W1 ++ + - ++ ++ - -/-- - 0 + + 0 0 --/0 -- ?/+ + +/- 0 - 0 Wickwar W2 ++ + - ++ ++ - +/-- - 0 + + ? 0 --/0 -- ?/+ + +/- 0 - 0

SGC WFCH1 + + +/- ++ ++ - -- - 0 + + ? - - -- ?/- +/- +/- 0 +/- 0 Winterbourne, WFCH2 + + +/- ++ ++ - -- - 0 + + ? 0 - -- ?/+ ++ +/- 0 +/- 0 Frampton, Coalpit Heath WFCH3 + - - ++ ++ - -- - 0 + + -- ? --/- -- ?/+ +/- +/- 0 +/- 0 WFCH4 + - +/- ++ ++ - +/- - 0 + + ? 0 --/0 -- -- +/- +/- 0 +/- 0 WFCH5 + 0 +/- ++ ++ - -- - 0 + + ? ? -- -- ?/- +/- +/- 0 +/- 0

HEARING STATEMENT

APPENDIX 3 – GREEN BELT MATTERS DOCUENT

This is enclosed as a separate document

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HEARING STATEMENT

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Land West of Pucklechurch

Green Belt Matters

Prepared by: The Environmental Dimension Partnership Ltd

On behalf of IM Land

May 2019 Report Reference edp3485_r011b

Land West of Pucklechurch Green Belt Matters edp3485_r011b

Contents

Section 1 Introduction ...... 1

Section 2 Landscape Related Designations and Policy ...... 13

Section 3 Greenbelt Assessment ...... 19

Section 4 Conclusions ...... 29

Appendices

Appendix EDP 1 Assessment Methodology and Criteria

Appendix EDP 2 Green Belt Analysis: Pucklechurch

Appendix EDP 3 Green Belt Analysis: Coalpit Heath

Appendix EDP 4 Green Belt Analysis: Yate

Plans

Plan EDP 1 Strategic Development Area Locations (edp3485_d051a 23 May 2019 WG/FM)

Plan EDP 2 Environmental Planning Context (edp3485_d004c 23 May 2019 WG/FM)

Plan EDP 3 Landscape Character and Features (edp3485_d010c 23 May 2019 AL/WG)

Plan EDP 4 Topography Plan (edp3485_d001a 20 May 2019 WG/FM)

This version is intended for electronic viewing only Report Ref: edp3485_r011 Author Formatted Peer Review Proofed by/Date 011_DRAFT FM ER - - 011a FM - - SC 230519 011b - ER - -

Land West of Pucklechurch Green Belt Matters edp3485_r011b

Section 1 Introduction

Introduction

1.1 This briefing paper has been prepared on behalf of IM Land by The Environmental Dimension Partnership Ltd (EDP), to provide an overview of the Green Belt Matters of Land to the West of Pucklechurch (hereafter referred to as ‘the site’).

1.2 The purpose of EDP’s work is to advance the current understanding of the Green Belt considerations and provide evidence of the suitability of the site for sustainable development in this regard. In addition, a high-level Green Belt review of the proposed SDL’s requiring release within South Gloucestershire is also considered.

1.3 EDP is an independent environmental consultancy providing advice to landowner and property development clients in the public and private sectors in the fields of landscape, ecology, heritage, arboriculture and masterplanning. The company operates throughout the UK from offices in Cirencester, Cardiff, Cheltenham and Shrewsbury. Details can be obtained at www.edp-uk.co.uk.

1.4 This appraisal has been informed by desk studies and a number of site walkovers, undertaken between December 2016 and May 2019. The information derived is discussed below.

The Site

Pucklechurch

1.5 The site lies at the western edge of Pucklechurch and to the east of Bristol within South Gloucestershire District. The site contains a mixture of land uses, including agricultural land divided by tree belts and hedgerows, an underground reservoir, numerous farm buildings, residential dwellings (including those along Parkfield Rank) and other urban fringe land uses such as fields in equestrian use.

1.6 The site is enveloped by transport routes of varying grades and tree cover. The B4465 and the settlement edge of Pucklechurch form the site’s eastern boundary, the B4465, Shortwood delineates the southern boundary of the site and the northern boundary is formed by the M4 motorway. The western boundary is defined by the minor roads of Parkfield Rank, Parkfield Road, Coxgrove Hill and an access road leading to Park Glen and Greatwood. Beyond the western boundary is the Pucklechurch Ridge.

1.7 The character of the site is influenced by both settlement, transport routes (minor and major road) and the urban fringe land uses within the site itself.

1 Land West of Pucklechurch Green Belt Matters edp3485_r011b

Coalpit Heath SDL

1.8 The location of this SDL is only available in indicative form, the approximate extents have been reproduced on Plan EDP 1. The SDL is at the eastern edge of Coalpit Heath, the current land use is agricultural, divided by tree belts and hedgerows. The SDL has a rolling topography, with a local ridge along the eastern extent. There is an extensive network of Public Rights of Way (PRoW) across the site which provide a good level of permeability with the settlement edge and surrounding landscape.

1.9 The SDL is broadly defined by the settlement edge and Badminton Road to the west, the mainline railway to the south, Frog Lane and a linear tree belt to the east and Frog Lane to the north. Beyond the eastern extents is agricultural land, woodland blocks and commercial buildings.

1.10 The character of the site is influenced by both settlement, transport routes (minor and major road and rail) and the commercial land uses, specifically to the north-east.

Yate SDL

1.11 The location of this SDL is only available in indicative form, the approximate extents have been reproduced on Plan EDP 1. The SDL is at the western edge of Yate, the current land use is agricultural, divided by tree belts and hedgerows. The SDL has a gently rolling topography and is crossed by several PRoW which provide access from Yate toward Coalpit Heath and Iron Acton to the west.

1.12 The SDL is broadly defined by, and wraps around the western, north-western and south- western settlement edge of Yate. The southern end is abutted by the mainline railway, with the western boundary broadly following a minor water course. Beyond the northern and western SDL extents is agricultural land, woodland blocks and a large solar farm.

1.13 The character of the site is strongly influenced by both settlement, transport routes (particularly rail given the elevated position of both the Birmingham to Bristol Mainline and the London to Swansea mainline at Westerleigh Junction on the southern edge of the SDL), adjoining commercial land uses and the Solar Farm immediately beyond the western extent.

Planning Background

Pucklechurch

1.14 The site was considered in the South Gloucestershire ‘Strategic Green Belt Assessment’ (December 2011) as part of Area 17. The document assesses each area against the five NPPF purposes and concluded in relation to Area 17 that:

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“The ridgeline currently performs an important purpose in preventing urban sprawl and functions as the rural backdrop to the urban area, particularly as the Emersons Green East development area will abut it. The green belt area to the east of the ridgeline preserves Pucklechurch as a separate settlement, open views from the Cotswold Area of Outstanding Natural Beauty and prevents urban sprawl. Both of these areas are a considerable distance from significant employment or services in the existing urban area and if green belt was lost would result in urban sprawl and the loss of open countryside which provides a setting from Bristol and the Cotswold Area of Outstanding Natural Beauty.”

1.15 The site was also considered in the West of England Joint Spatial Plan – Green Belt Assessment (November 2015) as Cell 26. The document assesses each cell against the five NPPF purposes and concluded in relation to Cell 26 that:

“The Green Belt in this cell directly serves purposes 1, 3 and 5;

Checks the sprawl of the urban area; and

Safeguards agricultural land and woodland from encroachment”

1.16 The site was promoted previously by Colliers as a potential strategic growth option at the issues and options consultation stage of the West of England Joint Spatial Plan. Representations at that time included a brief consideration of Green Belt Purposes in relation to the site as follows:

“Land to the West of Pucklechurch is constrained by the natural topography that drops steeply towards Lyde Green and forms a natural green and open boundary to the unrestricted sprawl of North East Bristol and allocation of Lyde Green;

The Bristol and Bath Cycle Path also provides an elevated barrier to Lyde Green and allows for a degree of separation to be legible.

The Green Belt Assessment identifies that the Land to the West of Pucklechurch also does not contribute to the purpose of preventing towns from merging into one another;

All areas of Green Belt are considered to assist in safeguarding the countryside from encroachment, however the land to the West of Pucklechurch is not unrestricted countryside, as the topography provides a natural barrier to development and the landscape therefore lends itself to protection towards the most westerly fringe of the site; …”.

1.17 It concludes that:

”…the performance of the land to the west of Pucklechurch in respect of releasing it from the Green Belt, the site is the least worse case scenario as it performs the least amount of reasons for keeping land within the green belt.”

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1.18 The site was subject to further assessment in the West of England Joint Spatial Plan - Green Belt Assessment Part 2 (November 2016) which subdivided Cell 26 into three smaller units a, b and c. The site being split across units 26b and 26c (Figure EDP 1.1). The document is a second stage of assessment at the JSP level which examines smaller parcel sizes.

Figure EDP 1.1: Extract from Joint Spatial Plan Green Belt Assessment Stage 2 (2016) illustrating sub-division of site across parcels 26b and 26c.

1.19 In relation to Cell 26b it concludes that, in relation to purpose 1, the site makes a major contribution:

“The south west edge and western edge of this cell are adjacent to Green Belt cells which have a major role in preventing unchecked sprawl from the East Fringe, that would have potential to cause coalescence with Pucklechurch, 2.1km from the existing east fringe of the urban area. Although this cell is not immediately adjacent the east fringe the cell is directly adjacent the western edge of Pucklechurch. Given the direct link to the urban area provided by the B4456 in the south of the cell, and lack of features in adjoining cells adjacent the East Fringe (26a and 28(a)), Green Belt in this cell is a major feature preventing potential sprawl from the East Fringe and causing coalescence with Pucklechurch.”

1.20 In relation to purpose 2 and 4, it concludes that assessment is not applicable.

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1.21 In relation to Cell 26b it concludes that, in relation to purpose 3, the site makes a contribution:

“Between the urban edge and Pucklechurch this relatively large Green Belt cell is open farmland with ranging topography and good connections visually and physically to the wider countryside.”

1.22 In the round it concludes that the cell makes a major overall contribution to Green Belt purposes:

“This cell along with cells 26a and 28a makes major role in preventing sprawl from the Bristol east fringe and coalescence with Pucklechurch. This cell in particular prevents potential sprawl from the East Fringe along the B4456.”

1.23 In relation to Cell 26c it concludes that, in relation to purpose 1, the site makes a major contribution:

“The south and western edge of this cell are adjacent two Green Belt cells which have a major role in preventing sprawl from the East Fringe, that would have potential to cause coalescence with Pucklechurch. Although this cell is not immediately adjacent the east fringe (between 0.6 and 0.8km), the cell is directly adjacent the northern edge of Pucklechurch. Given the lack of features in adjoining cells adjacent the East Fringe (26a) and (26b) Green Belt in this cell makes a major contribution to preventing potential sprawl from the East Fringe causing coalescence with the northern edge of Pucklechurch.”

1.24 In relation to purpose 2 and 4, it concludes that assessment is not applicable.

1.25 In relation to Cell 26c it concludes that, in relation to purpose 3, the site makes a contribution:

“Between the urban edge, Pucklechurch and M4 corridor, this Green Belt cell is open farmland with ranging topography and good connections visually and physically to the wider expanse of Green Belt to the east.”

1.26 In the round it concludes that the cell makes a major overall contribution to Green Belt purposes:

“This cell along with adjoining cells 26a and 26b makes a major contribution to preventing potential unchecked sprawl from the East Fringe causing coalescence with Pucklechurch. Green Belt within the cell protects the open expanse of countryside here from encroachment.”

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Coalpit Heath SDL

1.27 The site was considered in the South Gloucestershire ‘Strategic Green Belt Assessment’ (December 2011) as part of Area 17. The document assesses each area against the five NPPF purposes and concluded in relation to Area 17 that:

1.28 The site was also considered in the West of England Joint Spatial Plan – Green Belt Assessment (November 2015) as Cell 26. The document assesses each cell against the five NPPF purposes and concluded in relation to Cell 26 that:

“The Green Belt in this cell directly serves purposes 1, 3 and 5;

Checks the sprawl of the urban area; and

Safeguards agricultural land and woodland from encroachment.”

1.29 The SDL was subject to assessment in the West of England Joint Spatial Plan - Green Belt Assessment Part 2 (November 2016) which considered the entire SLD within Cell 21d (Figure EDP 1.2). The document is a second stage of assessment at the JSP level.

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Figure EDP 1.2: Extract from Joint Spatial Plan Green Belt Assessment Stage 2 (2016) illustrating the location of the SDL within parcels 26b and 26c.

1.30 In relation to purpose 1 and 4, Cell 21d it concludes that the SDL makes no contribution.

1.31 In relation to purpose 2, it concludes that the cell makes a contribution:

“This Green Belt cell contains land that surrounds the east side of Coalpit Heath and contains the A432 that links the North Fringe to Yate. If developed it would reduce the distance between Yate and Coalpit Heath from 1.45km to 0.8km. By preventing development along the conduit road the A432, assisting in keeping the narrowest point between Yate and Coalpit Heath open, Green Belt in this cell makes a contribution to reducing perceptions of visual and physical merger of the North Fringe, through Coalpit Heath and into the western boundary of Yate.”

1.32 In relation to purpose 3, it concludes that the cell makes a contribution:

“This Green Belt cell is a mix of open agricultural land. Green Belt in the cell is linked physically and visually to wider open farm land and Green Belt in the north and east of the district. Green Belt within the cell safeguards the countryside here from encroachment.”

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1.33 In the round it concludes that the cell makes an overall contribution to Green Belt purposes:

“Cell makes a contribution to preventing potential merger of the North Fringe and Yate, by preventing development along the A432 between Yate and Coalpit Heath and keeping the narrowest point between Coalpit Heath and Yate open.”

Yate

1.34 The site was considered in the South Gloucestershire ‘Strategic Green Belt Assessment’ (December 2011) as part of Area 17. The document assesses each area against the five NPPF purposes and concluded in relation to Area 17 that:

1.35 The site was also considered in the West of England Joint Spatial Plan – Green Belt Assessment (November 2015) as Cell 26. The document assesses each cell against the five NPPF purposes and concluded in relation to Cell 26 that:

“The Green Belt in this cell directly serves purposes 1, 3 and 5;

Checks the sprawl of the urban area; and

Safeguards agricultural land and woodland from encroachment.”

1.36 The Yate SDL was subject to assessment in the West of England Joint Spatial Plan - Green Belt Assessment Part 2 (November 2016) which subdivided the SDL into three Cells 22a, 21c and 21e (Figure EDP 1.3). The document is a second stage of assessment at the JSP level which examines smaller parcel sizes.

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Figure EDP 1.3: Extract from Joint Spatial Plan Green Belt Assessment Stage 2 (2016) illustrating sub-division of the SDL across parcels 22a, 21c and 21e.

1.37 In relation to purpose 1, 2 and 4, it concludes that assessment is not applicable.

1.38 In relation to purpose 3, the SDL makes a contribution:

“This area of Green Belt marks the beginning of a large, wide open area of countryside and Green Belt to the north and west of Yate. There are relatively few urbanising features within this area of Green Belt and wider area beyond, limited to agricultural buildings and uses. The southern edge of the Green Belt is partially physically and visually separated from wider Green Belt to the south by the path of the extant railway track to Thornbury. However, the cell has good connectivity to the wider expanse of open countryside west and north of the cell.”

1.39 In the round it concludes that the cell makes an overall contribution to Green Belt purposes:

“Green Belt in the cell is open, in agricultural use and generally well connected to the wider Green Belt and countryside to the east and north. There are very few urbanising features in this area of Green Belt and wider areas of the east. It is therefore considered that Green Belt designation in this location assists in safeguarding wider, open countryside from encroachment, particularly from potential development from Yate’s western and northern edge.”

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1.40 In relation to Cell 21c it concludes that, in relation to purpose 1 and 4, the SDL makes no contribution.

1.41 In relation to Cell 21c it concludes that, in relation to purpose 2, the site makes a contribution:

“This Green Belt cell contains lands that surrounds the west of Yate and the A432, towards Coalpit Heath. If developed it would reduce the distance between Yate and Coalpit Heath from 1.45km to 0.8km. By preventing development along the conduit road the A432, Green Belt in this cell makes a contribution to reducing perceptions of visual and physical merger of the North Fringe, into the western boundary of Yate, towards Coalpit Heath.”

1.42 In relation to Cell 21c it concludes that, in relation to purpose 3, the site makes a contribution:

“This Green Belt cell is a mix of open agricultural land and the washed over settlement of Nibley. Green Belt in the cell is linked physically and visually to wider open farm land and Green Belt in the north of the district. Green Belt within the cell safeguards the countryside here from encroachment.”

1.43 In the round it concludes that the cell makes an overall contribution to Green Belt purposes:

“Cell makes a contribution to limiting potential merger in the corridor from North Fringe and Yate, by preventing development along the A432 between Yate and Coalpit Heath. It also assists in safeguarding the countryside from encroachment.”

1.44 In relation to Cell 21e it concludes that, in relation to purpose 1 and 4, the SDL makes no contribution.

1.45 In relation to Cell 21e it concludes that, in relation to purpose 2, the site makes a contribution:

“This Green Belt cell contains lands that surrounds the west side of Yate and contains the A432 that links the North Fringe to Yate. If developed it would reduce the distance between Yate and Coalpit Heath from 1.45km to 0.65km. By preventing development along the conduit road the A432, assisting in keeping the narrowest point between Yate and Coalpit Heath open, Green Belt in this cell makes a contribution to reducing perceptions of visual and physical merger of the North Fringe, through Coalpit Heath into the western boundary of Yate.”

1.46 In relation to Cell 21e it concludes that, in relation to purpose 3, the site makes a contribution:

“This Green Belt cell has a significant part of its land covered by a solar farm reducing its open character. The remainder of the cell is open agricultural land where the cell assists in safeguarding the countryside from encroachment.”

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1.47 In the round it concludes that the cell makes an overall contribution to Green Belt purposes:

“Cell makes a contribution to limiting potential merger of the North Fringe and Yate, by preventing development along the A420 between Yate and Coalpit Heath and keeping the narrowest point between Coalpit Heath and Yate open. It also assists in safeguarding countryside from encroachment.”

1.48 In the wider JSP and local plan context, the delivery of Yate and Coalpit Heath SDL’s, introduced above, will require release from the Green Belt. Table EDP 1.1 summarises the findings of the West of England Joint Spatial Plan - Green Belt Assessment Part 2 relating to the site and the proposed SDL locations. Whilst other JSP authorities have undertaken more detailed Green Belt review as part of the local plan process, there is yet, nothing more detailed contained within the South Gloucestershire emerging evidence base. Whilst the assessment above considers the release of the two adjoining SDL locations, it doesn’t give any consideration to the potential harm of in combination effect of the proposed SDLs or define clearly, new boundaries, using physical features that are readily recognisable and permanent.

1.49 The purpose of this assessment, undertaken by an appropriately qualified Landscape Architect, is to advance the current understanding of the performance in landscape and visual terms of the site against the five purposes of the Green Belt, and provide a commentary on the suitability of the site for sustainable development in this regard with reference to the proposed SDL release within South Gloucestershire.

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Table EDP 1.1: Summary of JSP Green Belt Part 2 Assessment JSP Green Belt Part Purpose 1 - to Purpose 2 - to Purpose 3 - to assist Purpose 4 - to Overall Contribution 2 Cell check the prevent in safeguarding the preserve the setting unrestricted sprawl neighbouring towns countryside from and special of large built-up merging into one encroachment character of historic areas another towns Pucklechurch South 26b Major Contribution - Contribution - Major Contribution Pucklechurch North 26c Major Contribution - Contribution - Major Contribution Yate SDL 21c - Contribution Contribution - Contribution Yate SDL 22a - Contribution - Contribution Yate SDL 21e - Contribution Contribution - Contribution Coalpit Heath 21d - Contribution Contribution - Contribution

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Section 2 Landscape Related Designations and Policy

2.1 Landscape related designations are shown on Plan EDP 2:

• The site falls within the Bristol Green Belt;

• The boundary of the Cotswold Area of Outstanding Natural Beauty (AONB) lies approximately 3km to the east of the site;

• The site does not lie within or directly adjacent to a registered park and garden. However, Dyrham Park Registered Park and Garden (RPG) falls some 4km to the east of the site;

• Parts of the eastern and southern boundaries are adjacent to conservation areas, which contains a number of listed buildings;

• The site contains two grade II* listed buildings (Dennisworth Farmhouse and associated Barn);

• There are no Tree Preservation Orders (TPO’s) on or adjacent to the site; and

• There is public right of access onto the site via PRoW routes. However, none of the site is Open Access Land.

National Designations

2.2 The site lies within the Bristol Green Belt, where the Green Belt boundary meets the eastern settlement edge of Bristol. Pucklechurch itself is not ‘washed over’ by the Green Belt and the settlement currently falls outside the designation.

Green Belt

2.3 The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. As such, Green Belt is a planning policy designation rather than a landscape designation based on landscape character and value.

2.4 The National Planning Policy Framework (NPPF) paragraph 134 sets out five purposes of the Green Belt, which are listed below:

• “To check the unrestricted sprawl of large built-up areas;

• To prevent neighbouring towns merging into one another;

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• To assist in safeguarding the countryside from encroachment;

• To preserve the setting and special character of historic towns; and

• To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”

2.5 The NPPF sets out guidelines for local planning authorities in relation to Green Belts including: the desire to plan positively to enhance their beneficial use, looking for opportunities to provide access, outdoor sport, and recreation; and to retain and enhance landscapes, visual amenity, and biodiversity; or to improve damaged and derelict land.

2.6 Guidance in paragraphs 80 and 84 makes clear that, when reviewing Green Belt boundaries, local planning authorities (LPAs) should take account of the need to promote sustainable patterns of development; they should consider the consequences for sustainable development of channelling development towards urban areas, towns, and villages within the Green Belt or towards locations outside the Green Belt boundary.

2.7 Also of relevance to this report is guidance in paragraph 84 with regard to defining boundaries, which states that local authorities should inter alia:

• Not include land that it is unnecessary to keep permanently open; and

• Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.

2.8 The site has not been included in the Joint Spatial Strategy with a number of reasons cited, namely transportation issues, access to major areas of employment, topographical, ecological and archaeological constraints, impression of potential sprawl and separation in the locality undermining the objectives of the Green Belt.

2.9 This report addresses the site role in relation to the purposes of the Green Belt.

Cotswolds Area of Outstanding Natural Beauty

2.10 The site does not lie within or directly adjacent to the Cotswold AONB. However, it does lie within approximately 3km of the AONB’s western boundary and the setting of the AONB is a consideration. However, it is noted that there are several tree belts and woodlands separating the site from the AONB boundary as does the settlement of Pucklechurch to the east and the M4 to the north.

Registered Park and Garden

2.11 Dyrham Park RPG falls some 4km to the east of the site but is not visible from it. This RPG is separated from the site by a number of roads and intervening tree belts, fields and boundaries associated with these features. These features, are found to substantially limit, or detract from, the possibility of intervisibility between Dyrham RPG and the site.

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Heritage and Archaeology

2.12 The site contains the Grade II* Dennisworth Farmhouse and its associated Grade II listed barn and the Brandy Bottom Colliery scheduled monument. The Pucklechurch and Siston Conservation Areas are located to the east and south of the site. In terms of non-designated heritage assets (below-ground archaeology), there is a good potential of encountering Roman archaeology within the site, although this may only comprise ‘low’ interest items, such as field boundaries. In addition, there is a possible Bronze Age burial mound along the southern edge of the site.

Ecology

2.13 There are no statutory designations within the site. Some habitats on the site’s peripheries (adjacent to the M4 and within the Pucklechurch Ridge) are subject to non-statutory SNCI designations.

2.14 There is no Ancient Woodland on or adjacent to the site and none of the trees within or adjacent to the site boundary have TPO’s.

Local Policy

2.15 Local landscape policy of relevance to the site is contained within South Gloucestershire Core Strategy (CS) 2006-2027, adopted 11 November 2013, as well as a number of saved policies from the South Gloucestershire Local Plan (SGLP) 2006. Policies relevant to this site are noted below.

2.16 These include:

• Policy CS1 High Quality Design – Development will need to demonstrate that sitting, form, scale, and height is informed by the site and its wider context and that existing landscape, nature conservation, amenity and PRoW are safeguarded and enhanced through development;

• Policy CS5 Location of Development – This manages the location and scale of development. The policy states that in open countryside new development is to be limited and that the extent of the Green Belt will remain relatively unchanged to that shown in the South Gloucestershire Local Plan. It states that any development in the Green Belt should be small scale infill within existing settlement boundaries and that other proposals should comply with provisions within the NPPF and relevant saved local plan policies within the Core Strategy;

• Policy CS9 Managing the Environment and Heritage – This identifies that the natural and historic environment is finite and irreplaceable, new developments should therefore: conserve, respect and enhance heritage assets; conserve and enhance the natural environment, by avoiding or minimising impacts on biodiversity and

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geodiversity; and conserve and enhance the character, distinctiveness, quality and amenity of the landscape;

• Saved SGLP Policy L1 – This states that “In order that the character, distinctiveness, quality and amenity of the landscapes of South Gloucestershire are conserved and enhanced, new development will be permitted only where:

(a) Those attributes of the landscape which make a significant contribution to the character of the landscape are conserved and where possible enhanced;

(b) Those features in or of the landscape which make a significant contribution to the character or distinctiveness of the locality are retained, protected and managed in a manner which ensures their long-term viability; and

• Saved SGLP Policy GB1 – This aims to protect the Green Belt through limitations on the: a) construction of new buildings; and b) the change of use of land or existing buildings. The proposals include the replacement of one building and the extension of two buildings so that it is assumed that section b) is relevant. This section states that within the Green Belt permission will only be given for the change of use of land or existing buildings where:

“1. It would not have a materially greater impact than the present authorised use on the openness of the Green Belt and would not conflict with the purpose of including land in it;

2. The buildings are of permanent and substantial construction and are capable of conversion without major or complete reconstruction; and

3. The form, bulk and general design of the buildings are in-keeping with their surroundings.

Any proposals for development within or conspicuous from the Green Belt which would have an adverse impact on the visual amenity of the Green Belt will not be permitted.”

2.17 Policy GB1, therefore, sets a number of tests for development or redevelopment within the Green Belt, which are of some relevance in landscape terms. These tests include:

• The impact of the proposal on the ‘openness’ of the Green Belt;

The acceptability of the form, bulk and general design of the buildings in relation to their surroundings; and

• That any proposals for development within the Green Belt should not have an adverse effect on its visual amenity.

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2.18 The site also lies within the ‘Forest of Avon’ Community Forest within which it is an objective to achieve a range of woodland and open space uses;

2.19 There are no other material statutory or non-statutory constraints that would preclude development of the site.

2.20 However, local planning policy also contains general policy of relevance to the site, which seeks to ensure that proposals:

• Safeguard and enhance amenity and PRoW;

• Conserve, respect and enhance heritage assets;

• Conserve and enhance the natural environment;

• Conserve and enhance the character, distinctiveness, quality and amenity of the landscape;

• Conserve and, where possible, enhance those attributes of the landscape which make a significant contribution to its character; and

• Retain, protect and manage, in a manner which ensures their long-term viability, those features in or of the landscape which make a significant contribution to its character or distinctiveness.

Policy Discussion

2.21 As described above, the whole of the site lies within the designated Green Belt. This is a long-standing and well-established development control tool which is embodied within the saved SGLP at Policy GB1.

2.22 As noted in the Spatial Strategy Consultation Document:

“A sizeable proportion (48%) of the West of England is part of the Bristol-Bath Green Belt. This has significant implications for the spatial strategy, particularly reflecting the strategic priority to retain the overall function of the Green Belt. The advice in NPPF para 83 is ‘Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.”

2.23 In reviewing the JSP assessment methodology and summary contained in Section 1, there are four matters which require consideration:

• With regard to green belt purpose 1, the authors have conflated ‘unrestricted sprawl’ issues with coalescence. This approach evidently does not correlate to Green Belt purpose 1, nor the methods; and

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• Conversely, and with regard to purpose 2, the authors have accepted that the land between Bristol and Pucklechurch does not contribute to the purpose of preventing the ‘merging’ of towns;

• Whilst a wholescale review of the SDLs necessitating Green Belt release has not be undertaken, a high-level appraisal of the role of the Green Belt between Yate and Coalpit Heath has. In this instance, it would appear that very little weight appears to have been given to the manner in which growth might be perceived from the adjoining landscape and settlement edges as part of a combined release, where there could be up to a 50% reduction in the ‘gap’ (As illustrated on Plan EDP 1). The evidence does not determine robust and defensible boundaries, it merely indicates an aspiration for a ‘strategic green gap’ to separate adjoining SDLs. It is unclear if robust and defensible boundaries can be established at both the western edge of Yate and the eastern edge of Coalpit Heath. Furthermore, in the instance of Yate and Colapit Health, a significant swath of the ‘strategic green gap’ comprises an operational solar farm, which would erode the function and role of the retained Green Belt at this location; and

• In relation to cells 26b and 26c, the JSP assessment seeks to elevate the parcels role by attributing an in-combination role with the adjoining cell (26a - Pucklechurch Ridge), which does in fact provide a defensive boundary and separation from Bristol. This approach is not consistent across the evidence base.

2.24 The Consultation document is clear that it is not possible to sustainably accommodate all the identified West of England growth needs entirely outside the Green Belt and thus some development will need to take place within the Bristol and Bath Green Belt. This report therefore assesses the site against the five purposes of the green belt from a landscape and visual perspective, to give some guidance as to the potential appropriateness of the site as a Green Belt Release Option. This assessment is summarised in Section 3.

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Section 3 Green Belt Assessment

3.1 This Green Belt Assessment has been undertaken by an appropriately qualified Landscape Architect and follows the assessment criteria and methodology outlined below.

Assessment Criteria

3.2 As noted in the NPPF, paragraph 80 and Section 2 above, the Green Belt serves five purposes. For each NPPF purpose, criteria have been determined that allows for a more comprehensive analysis to be undertaken, in landscape and visual terms, of the contribution the site makes to the function of the Green Belt in this location. The criteria for each purpose are described in more detail below.

Purpose 1: To Check the Unrestricted Sprawl of Large Built-up Areas

3.3 This is a test that considers whether any built form is contained within the site or if the site is able to prohibit further development. Commonly this is ribbon development, but may also be piecemeal development in isolated areas or along settlement edges. A site may have already been compromised by some form of development, in which case it is relevant to consider the extent to which that development has eroded the sense of openness – this being whether or not there is a sense that the site within the Green Belt is still open and absent of development.

3.4 Sprawl may also be discouraged by defensible boundaries that are either natural (e.g. topography, woodland, water course) or man-made features such as a road, railway line, or settlement edge. These may be within the site or share a boundary with it. Sites that do not contain defensible boundaries contribute towards greater openness.

Purpose 2: To Prevent Neighbouring Towns Merging into One Another

3.5 The wording of the NPPF refers to ‘towns’, but in the context of this assessment study area, the Green Belt affects a considerably smaller geographical scale, in which it is more relevant to consider the potential for merging of neighbouring settlement edges as well as distinct settlement areas which might be defined as towns. In essence, the purpose seeks to avoid coalescence of built form. This can be perceived in either plan view or ‘on the ground’ by intervening natural or man-made features.

3.6 The interpretation of ‘merging’, in terms of geographic distances, differs according to the study area. Whilst a review of distinct towns might need to account for distances over several kilometres, when considering gaps between smaller settlements, the range can be much smaller with distances reducing to as little as 100m in some cases. It is of note that susceptibility to ‘merging’ depends on the extent of openness between two settlements and each situation needs to be reviewed in relation to the local landscape and visual context.

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Purpose 3: To Assist in Safeguarding the Countryside from Encroachment

3.7 In terms of Green Belt, the ‘countryside’ is the landscape outside of the current development limits, which is generally defined by key characteristics such as hedgerow networks, varying field patterns, presence/absence of woodland, downland character, topographical features or open space, etc. Countryside is likely to be undeveloped land that is typically rural and often managed for agriculture or forestry, or simply kept as an open natural or semi-natural landscape. It may, however, contain man-made features such as historic landmarks or isolated properties, or even larger areas of settlement.

3.8 This assessment is based on the key landscape characteristics of the site and its surroundings as well as the visual context.

3.9 Sites that are highly representative of the key landscape characteristics, and exhibit them in good condition, make a stronger contribution towards safeguarding the countryside than land that is less representative of the landscape character area or contains features that are in poorer condition. This allows a relative and qualitative ‘value’ element to be applied to landscapes.

3.10 The matter of ‘encroachment’ is also a judgement that considers whether or not built form (such as residential development and/or related urbanising features such as street lighting, road signs, road infrastructure, etc.) is found in the site or affects it and also the degree to which it has preserved the key characteristics or severed them from the wider countryside. A site which has limited or no urbanising influences has a stronger role in safeguarding countryside.

3.11 Finally, encroachment can also be prohibited by the presence or absence of particular natural or man-made features that separate existing settlement edges from the wider countryside. Typically, it is large man-made features such as dual carriageways, or motorways; natural features might include woodland, large water bodies such as lakes and rivers or deep, steeply sloped valleys. Such features may border a site or be contained wholly or partially within it.

3.12 However, natural features in particular, including woodland, rivers or ridgelines, may suffer a loss of their integrity as prominent features within the landscape if development is progressed upon, or near, them. These features should therefore be safeguarded.

Purpose 4: To Preserve the Setting and Special Character of Historic Towns

3.13 The subject of setting and special character in the context of historic towns should be examined on a site by site basis, by specialist heritage consultants. However, the conservation area local heritage designation allows the assessment to acknowledge that historic cores exist.

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Purpose 5: To Assist in Urban Regeneration, by Encouraging the Recycling of Derelict and Other Urban Land.

3.14 The consultation exercise considers sites within the Green Belt as well as the redevelopment of urban land with the presumption in favour of development opportunities outside the Green Belt.

Methodology

3.15 EDP have developed a methodology for Green Belt Assessment, which is based on landscape and visual assessment methodology with regard to the purposes of the Green Belt and our experience of Green Belt reviews.

3.16 The site is scored against the criteria listed for each purpose as shown in Appendix EDP 1, with criteria scoring set out in Table EDP 3.1 below.

Table EDP 3.1: Scoring Criteria Score Contribution to the Green Belt Purpose 1 No contribution 2 Limited contribution 3 Strong contribution

3.17 The grading of overall scores reflect the contribution the site makes towards meeting the purposes of the Green Belt. This ensures that, whilst the NPPF does not require all five purposes, or tests, to be met simultaneously, the extent to which a site contributes to the criterion of a specific purpose will better inform the decision for it to be removed from the Green Belt, or retained within it.

3.18 The findings are presented in the Green Belt Assessment Table in Appendix EDP 2.

3.19 This assessment does not include consideration of the potential of the site to address all NPPF paragraphs relating to the Green Belt. This is, however, provided as part of the planning statement supporting the information submitted to the LPA.

3.20 The findings demonstrate that, out of a maximum score of 21, which would indicate that a site would be performing a strong role in achieving all Green Belt purposes, and a minimum score of 7, the site scores 12, which can be described as making a limited contribution. In comparison Yate SDL scores 15 and Coalpit Heath scores 15 which can also therefore be described as making a limited contribution.

3.21 A summary discussion of the findings in relation to each of the first four purposes is provided below for each site.

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Pucklechurch

Purpose 1: To Check the Unrestricted Sprawl of Large Built-up Areas

3.22 This assessment considers how the site and its features contribute towards the openness of the Green Belt and the potential to create a permanent boundary, should it be taken out of the designation. The site comprises a variety of land uses including built form, housing, urban fringe land uses, an underground reservoir and arable farmland with woodland, and hedgerows. The sense of openness is already limited to some extent. Further development of the site would contribute towards increasing the built form and therefore reduce the sense of openness experienced in views across the site where available.

3.23 The area is delineated by clearly definable boundaries that follow existing strategic roads to the north (M4) and south (The B4465 Shortwood). The B4465 and the settlement edge of Pucklechurch form the site’s eastern boundary. Should development be delivered in the manner indicated above and as shown on Plans EDP 3 and 4, a defensible boundary already exists to the west of the site - the Pucklechurch Ridge, which would provide definitive separation between Pucklechurch and Bristol. In more detailed terms, the western boundary would be defined by a series of minor roads including Parkfield Rank, Parkfield Road, Coxgrove Hill and an access road leading to Park Glen and Greatwood. The final southern section would be defined by a hedgerow with trees which forms the property boundary to Shortwood Lodge.

Purpose 2: To Prevent Neighbouring Towns Merging into One Another

3.24 Pucklechurch is a settlement in its own right and as such the proposals will seek to act as an extension to the settlement. Although on plan, development of the site would bring the settlement of Pucklechurch closer to Bristol, the Pucklechurch Ridge provides a clear separation. This green ridge would provide functional as well as visual separation between the settlements. It is such a strong landscape feature in its own right, the ridge height serving as a physical barrier in many regards as well as containing extensive woodland planting that performs a further visual containment function.

3.25 It is therefore considered that, development of the eastern portion of the site will not contribute to ‘unrestricted sprawl’ or ‘the merging of neighbouring towns’.

Purpose 3: To Assist in Safeguarding the Countryside from Encroachment

3.26 The site would represent an encroachment into open countryside. If it is accepted that the need is there, and exceptions exist, it would from an extension to the settlement of Pucklechurch. The site is abutted by existing development to the east and contained on all remaining sides by transport corridors, which together with other development forms on site play some part in the erosion of the site’s rural character In landscape character terms, the site currently has an urban fringe character in large part, with a fragmented mosaic of built, urban fringe, and agricultural land uses, and urban influences from adjacent settlement and transport routes.

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3.27 The Pucklechurch Ridge provides a strong physical separation to the west and the minor road network/woodland edge provides a strong, defensible boundary. The M4 provides a strong defensible boundary to the north and the Shortwood Road, a strong defensible boundary to the south. Thus, it is considered that the site could be developed as an extension to the settlement in a sustainable manner without inviting further encroachment into open countryside.

Purpose 4: To Preserve the Setting and Special Character of Historic Towns

3.28 The site is so far removed from the historic centres of any towns or cities in the area that it can have no function in relation to this purpose.

Purpose 5: To Assist in Urban Regeneration, by Encouraging the Recycling of Derelict and Other Urban Land

3.29 The site is entirely contained within the Green Belt and does not perform positively against this function.

3.30 It is considered that the site could reasonably be removed from the Green Belt and developed in accordance with the principles in the Proposed Land Use Masterplan without harm to the integrity of the Green Belt overall.

Coal Pit Heath SDL

Purpose 1: To Check the Unrestricted Sprawl of Large Built-up Areas

3.31 This assessment considers how the site and its features contribute towards the openness of the Green Belt and the potential to create a permanent boundary, should it be taken out of the designation. The site comprises predominantly agricultural land, development of the site would contribute towards increasing the built form and therefore reduce the sense of openness experienced in views across the site, including from the promoted route of The Dramway.

3.32 The area is delineated by the built edge of Coalpit Heath to the west, Frog Lane to the north and north-east, mature vegetation along the route of the disused railway line to the east, and the south wales railway line to the south. Across parts of the site there is some intervisibility with the edge of Yate, particularly the commercial units on Nibley Lane.

Purpose 2: To Prevent Neighbouring Towns Merging into One Another

3.33 Development of the site would bring the settlement of Coalpit Heath closer to Yate, for which there is currently visual connectivity across much of the site and neighbouring settlement edge. A definitive buffer would need to be provided.

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Purpose 3: To Assist in Safeguarding the Countryside from Encroachment

3.34 The site would represent an encroachment into open countryside. If it is accepted that the need is there, and exceptions exist, it would from an extension to the settlement of Coalpit Heath. Defensible boundaries appear to be present. However, the lack of consideration of the in-combination effect of a similar extension on the western edge of Yate does not appear to have been considered.

Purpose 4: To Preserve the Setting and Special Character of Historic Towns

3.35 The site is so far removed from the historic centres of any towns or cities in the area that it can have no function in relation to this purpose.

Purpose 5: To Assist in Urban Regeneration, by Encouraging the Recycling of Derelict and Other Urban Land

3.36 The site is entirely contained within the Green Belt and does not perform positively against this function.

Yate

Purpose 1: To Check the Unrestricted Sprawl of Large Built-up Areas

3.37 This assessment considers how the site and its features contribute towards the openness of the Green Belt and the potential to create a permanent boundary, should it be taken out of the designation. The site contains a mixture of agricultural land uses divided by hedgerows and mature trees. Beyond the western boundary is open countryside including rectilinear woodland blocks. There is currently a visual link between this land at the settlement edge of Coalpit Heath. Further development of the site would contribute towards increasing the built form and therefore reduce the sense of openness experienced in views across the site where available. To the north of the A432, the village of Nibley, which has a distinctly rural character, would be conjoined to Yate.

3.38 A new defensible boundary would need to be provided along the western edge.

Purpose 2: To Prevent Neighbouring Towns Merging into One Another

3.39 Development of the site would bring the settlement of Yate closer to Coalpit Heath, for which there is currently visual connectivity across parts of the site and from the existing settlement edge. A definitive buffer would need to be provided, within land currently containing a Solar Farm Nibley Lane and the Birmingham Bristol railway line currently present very strong defensible boundaries on the western edge of Yate. Given the Coalpit Heath SDL proposal, it is difficult to ascertain how an extension beyond these strong linear features could be justified. The in-combination effect and loss of identity of Nibley Village does not appear to have been fully considered and delineation of the clearly defensible boundary to the north of the A432 is also unclear. While Nibley Lane, Hope Road and Bridge

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Road present some opportunity for robust boundaries, existing village development beyond those roads could invite further encroachment.

Purpose 3: To Assist in Safeguarding the Countryside from Encroachment

The site has a strong urban fringe character with a relatively prominent urban edge along Nibley Lane and the railway lines and junction as well as the Solar Farm, all contributing to an erosion of the rural character of the area. At this stage it is not clear what would form clearly, defensible boundaries along the western and northern edges, and how the SDL would relate to the Solar Farm which forms a significant part of what would become a relatively narrow green swathe between Coalpit Heath and Yate, Nibley Lane and the Birmingham Bristol railway line currently present very strong defensible boundaries on the western edge of Yate. Given the Coalpit Heath SDL proposal, it is difficult to ascertain how an extension beyond these strong linear features could be justified. The in-combination effect and loss of identity of Nibley Village does not appear to have been fully considered and delineation of the clearly defensible boundary to the north of the A432 is also unclear. While Nibley Lane, Hope Road and Bridge Road present some opportunity for robust boundaries, existing village development beyond those roads could invite further encroachment.

Purpose 4: To Preserve the Setting and Special Character of Historic Towns

3.40 The site is so far removed from the historic centres of any towns or cities in the area that it can have no function in relation to this purpose.

Purpose 5: To Assist in Urban Regeneration, by encouraging the Recycling of Derelict and Other Urban Land

3.41 The site is entirely contained within the Green Belt and therefore does perform positively against this function.

Delineating Green Belt Boundaries

3.42 The NPPF requires that Green Belt boundaries are defined clearly, using physical features that are readily recognisable and likely to be permanent.

3.43 As illustrated in Figure EDP 3.1, a release at Pucklechurch could be readily facilitated with limited reinforcement along the western boundary.

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Figure EDP 3.1: Pucklechurch Site Green Belt Boundaries.

3.44 As illustrated in Figure EDP 3.2, a release at Yate, unless restricted to Nibley Lane and the railway line, would require significant reinforcement along the western and northern boundaries where few suitable features exist to form a robust edge

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Figure EDP 3.2: Yate SDL Green Belt Boundaries.

3.45 As illustrated below Figure EDP 3.3, a release at Coalpit Heath could be readily delineated with limited reinforcement along the northern and eastern boundaries.

Figure EDP 3.3: Coalpit Heath SDL Green Belt Boundaries.

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Section 4 Conclusions

4.1 This paper has provided an overview of Green Belt matters and provides landscape evidence of the suitability of the site for sustainable development in this regard.

4.2 The landscape and visual based assessment of how the site (Pucklechurch) and its features contribute towards the purposes of the Green Belt is summarised below:

• Purpose 1 – the site currently contains built development and is influenced by numerous detractors, which compromise its openness to a significant degree and give parts of the site a suburban character. The site has clear defensible boundaries on all sides;

• Purpose 2 – although development of the site would bring the settlement of Pucklechurch closer to Bristol, the Pucklechurch Ridge prevents any perceived merging;

• Purpose 3 – in landscape character terms, the site currently has a strong semi-urban character with a fragmented mosaic of built, urban fringe, and agricultural land uses; and urban influences from adjacent settlement and transport routes. Considered masterplanning as discussed above would safeguard the encroachment into the countryside;

• Purpose 4 – there is no proximity or intervisibility with the historic core of a town and thus the area does not perform against this function; and

• Purpose 5 – The site is entirely contained within the Green Belt and does therefore perform positively against this function. However, as demonstrated above, with the identified need for some development within the Green Belt, some development can occur in this location while, the Pucklechurch ridge continues to perform the essential functions of the Green Belt, preventing merging of settlements, encroachment and unrestricted sprawl.

4.3 Thus, it is considered that the site could reasonably be removed from the Green Belt and developed in accordance with the principles in the Concept Masterplan without harm to the integrity of the Green Belt overall.

4.4 Having undertaken a high-level review of two SDL’s within South Gloucestershire and in terms of the current evidence base, there are five matters of concern:

• With regard to Green Belt purpose 1, the authors have conflated ‘unrestricted sprawl’ issues with coalescence. This approach evidently does not correlate to Green Belt purpose 1, nor the methods; and

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• Conversely, and with regard to purpose 2, the authors have accepted that the land between Bristol and Pucklechurch does not contribute to the purpose of preventing the ‘merging’ of towns;

• Whilst a wholescale review of the SDLs necessitating Green Belt release has not be undertaken, a high-level appraisal of the role of the Green Belt between Yate and Coalpit Heath has. In this instance, it would appear that very little weight appears to have been given to the manner in which growth might be perceived from the adjoining landscape and settlement edges as part of a combined release, where there could be up to a 50% reduction in the ‘gap’ (as illustrated on Plan EDP 1). The evidence does not determine robust and defensible boundaries, it merely indicates an aspirational ‘strategic green gap’ to separate adjoining SDLs. As these defensible boundaries are critical to Purpose 1 and the prevention of sprawl, it seems unsatisfactory that this element of such a proposal has not been considered. Furthermore, in the instance of Yate and Colapit Health, a significant swath of the ‘strategic green gap’ comprises an operational solar farm, which would erode the function and role of the retained Green Belt at this location;

• As it currently stands, there is no substantive evidence setting out the methodology used, and/or the decisions made for delineating the boundaries of the proposed SDLs, this should be provided prior to confirmation of the SDLs as part of the JSP process.

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Appendix EDP 1 Assessment Methodology and Criteria

NPPF Para 80 Criteria Application of Criteria to Site and Criteria Score Green Belt Purpose

Purpose 1 Creates a clear, recognisable Does the site form a contiguous open buffer To check the distinction between urban between the existing settlement edge and the unrestricted fringe and open countryside. wider countryside? sprawl of large built-up areas a. Yes, the site is free of development and associated influences and strongly contributes to the openness of the Green Belt (score: 3); b. There is an absence of development within the site but it is overlooked by adjacent/nearby development (score: 2); and c. No, the site contains development and/or does not clearly define a distinction between the settlement edge and the open countryside (score: 1).

Defensible boundaries have Does the site have a defensible boundary a role in limiting unrestricted which can prevent sprawl? sprawl as they create the boundaries to Green Belt a. The site does not have a defensible boundary parcels. These may be within and therefore openness is greater (score: 3); the site or form part of its b. The site has a defensible boundary/- boundary. Such boundaries boundaries, which would need additional can be permanent, such as reinforcement (score: 2); and roads, steep topography, c. The site has a defensible boundary/- woodland or require boundaries, which do not require additional additional reinforcement reinforcement (score: 1). such as hedgerows and streams. Fences do not form defensible boundaries.

Purpose 2 Settlements maintain a clear Is the site well associated with the existing To prevent and sinuous edge. settlement edge? neighbouring towns merging a. The site is isolated from the settlement into one boundary and appears divorced from it (score: another 3); b. The site abuts one settlement boundary but is not divorced from it (score: 2); and c. The site abuts two or more settlement boundaries and therefore forms part of an indent (score: 1).

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NPPF Para 80 Criteria Application of Criteria to Site and Criteria Score Green Belt Purpose

Prevent loss or noticeable Given the distance between the whole of the reduction in distance site and next nearest settlement edge, what is between towns/settlement the effect of the perceived and actual edges; this may also be intervisibility or potential for coalescence? affected by agricultural land use or topography: a larger a. Immediate and clear intervisibility with next distance or more prominent nearest settlement edge (score: 3); topographical change would b. Partial visual association with next nearest be better capable of settlement edges (score: 2); and accommodating change than c. Limited or no visual association with next a narrow gap. nearest settlement edges (score: 1).

The gaps may contain different elements, be it natural (e.g. topography, woodland, agricultural land or large open spaces) or man-made features, which prevent merging.

Purpose 3 The countryside comprises To what extent does the site represent the key To assist in ‘key characteristics’ which characteristics of the countryside? safeguarding define the landscape and the the countryside way it is perceived, both a. The site is strongly representative of the key from visually and physically. characteristics and clearly connects with off- encroachment site key characteristics. (score: 3); b. The site comprises some representative key characteristics but there are few connections with off-site characteristics (score: 2); and c. The site comprises little or no key characteristics and there is limited or no connection with off-site characteristics (score: 1).

Encroachment: features such To what extent is the site urbanised, either by as speed signage and street on-site or off-site features? lighting affect the extent to which the countryside a. There are no urbanising features within the changes from rural to urban. site or directly influencing it (score: 3); b. There are several urbanising features affecting the site (score: 2); and c. There are many urbanising features affecting the site, which reduces its representativeness of the countryside (score: 1).

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NPPF Para 80 Criteria Application of Criteria to Site and Criteria Score Green Belt Purpose

Purpose 4 In the absence of What is the spatial and visual relationship To preserve the professional judgement on between the site and the historic core of the setting and setting and special character nearest towns? special on a site-by-site basis by character of heritage consultants, the a. The site shares a boundary with the historic historic towns criteria considers the core of the town, is partially or wholly within it proximity of the site to the or has clear intervisibility with the historic core historic core of a town. (score: 2); and

b. The site does not share a boundary with the town and/or there is no intervisibility with its historic core (score: 1).

Purpose 5 By association with the a. The site is in the Green Belt (score: 2); and To assist in Green Belt designation, urban would assist in urban b. The site is not in the Green Belt (score: 1) regeneration, regeneration by directing by encouraging development away from it. the recycling of derelict and other urban land.

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Appendix EDP 2 Green Belt Analysis: Pucklechurch

NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 1: To check Does the site form a The site contains a mixture of land uses, 1 the unrestricted contiguous open buffer including agricultural land divided by tree sprawl of large built- between the existing belts, hedgerows and, the reservoir, up areas settlement edge and numerous farm buildings, residential the other settlement dwellings (including those along Parkfield areas/wider Rank) and other urban fringe land uses countryside? including extensive horse use and a landfill. Pucklechurch Ridge to the west of the site provides a definitive boundary to development.

Are there any As shown on Plan EDP 4, this newly 1 defensible boundaries? proposed boundary follows strong defensible features such as roads and the Pucklechurch Ridge, with only short sections where some boundary reinforcement could be carried out to assimilate the development within its setting.

Purpose 2: To prevent Is the site well- The site lies adjacent to the western 2 neighbouring towns associated with the settlement edge of Pucklechurch. The merging into one existing settlement Pucklechurch Ridge along the length of another edge? the western boundary provides separation from Emersons Green in Bristol. The site is well associated with the settlement edge of Pucklechurch to the east.

What is the There is potential for limited intervisibility 1 intervisibility with the with Siston to the south. There will be next nearest intervisibility between the site and settlement edge? Pucklechurch.

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NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 3: To assist How representative is The site currently has a strong semi-urban 2 in safeguarding the the site of the key character with a mix of built, urban fringe, countryside from characteristics of the agricultural and recreational uses as well encroachment countryside? as urban influences from adjacent settlement and transport routes. There is also some deterioration of landscape fabric where hedgerows have been replaced with post and wire fences for horse paddocks and with complete removal of field boundaries associated with arable land use particularly in the central and northeastern portions of the site. Man-made landforms (such as the reservoir) have associated non-native planting to provide screening but is rather incongruous within the landscape. Comparatively, the countryside to the east is far more distinctive and representative of the host landscape character and makes a clear contribution to the setting of the AONB.

What is the influence The influence of urbanising features can 2 of urbanising features? be seen from all areas of the site. The settlement edge along the eastern boundary has a strong urbanising effect with the visual influence of residential dwellings, roads and street lighting. The central and north-east area of the site comprises a number of residential dwellings. The south and north-east area of the site abut both B4465 and the northern boundary abuts the M4, these areas are heavily influenced by the transport corridors, which are audible and visually legible as is the associated signage and junction with the A46. This site provides an area of land on the western edge of Pucklechurch that is physically and visually separated from the wider open countryside to the north, east and south.

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NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 4: To What is the nature of There is no proximity or intervisibility with 1 preserve the setting the spatial and visual the historic core of a town and thus the and special character relationship between area does not perform against this of historic towns the site and the function. historic core of the nearest town?

Purpose 5: Is the land within the The site is entirely within the Green Belt. 2 To assist in urban Green Belt regeneration, by encouraging the recycling of derelict and other urban land

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Appendix EDP 3 Green Belt Analysis: Coalpit Heath

NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 1: To check Does the site form a The SDL contains a mixture of 2 the unrestricted contiguous open buffer agricultural land uses divided by sprawl of large built- between the existing hedgerows. Beyond the eastern up areas settlement edge and boundary is open countryside including the other settlement rectilinear woodland blocks. There is areas/wider currently a visual link between this land countryside? and the settlement edge of Yate.

Are there any A new defensible boundary would need 2 defensible boundaries? to be provided along/beyond the eastern edge.

Purpose 2: To prevent Is the site well- The SDL is well associated with the 2 neighbouring towns associated with the settlement edge of Coalpit Heath to the merging into one existing settlement west. another edge?

What is the There is currently intervisibility across 2 intervisibility with the parts of the SDL and Yate. next nearest settlement edge?

Purpose 3: To assist How representative is This SDL is a mix of open agricultural 2 in safeguarding the the site of the key land which is physically and visually to countryside from characteristics of the the wider open farm land to the north encroachment countryside? and east.

What is the influence The influence of urbanising features can 2 of urbanising features? be seen across much of the SDL. The settlement edge along the western boundary has a strong urbanising effect with the visual influence of residential dwellings, roads and street lighting. Furthermore, across much of the SDL, the settlement edge of Yate is a discernible influence.

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NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 4: To What is the nature of There is no proximity or intervisibility 1 preserve the setting the spatial and visual with the historic core of a town and thus and special character relationship between the area does not perform against this of historic towns the site and the historic function. core of the nearest town?

Purpose 5: Is the land within the The SDL is entirely within the Green 2 To assist in urban Green Belt Belt. regeneration, by encouraging the recycling of derelict and other urban land

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Appendix EDP 4 Green Belt Analysis: Yate

NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 1: To check the Does the site form a The SDL contains a mixture of 2 unrestricted sprawl of contiguous open buffer agricultural land uses divided by large built-up areas between the existing hedgerows and mature trees. settlement edge and Beyond the western boundary is the other settlement open countryside including areas/wider rectilinear woodland blocks. There countryside? is currently a visual link between parts of this land at the settlement edge of Coalpit Heath and Iron Acton.

Are there any A new defensible boundary would 2 defensible boundaries? need to be provided along the western edge, parts of which currently comprise a Solar Farm.

Purpose 2: To prevent Is the site well- The SDL is well associated with the 2 neighbouring towns associated with the settlement edge of Yate to the east. merging into one existing settlement another edge?

What is the There will be intervisibility between 2 intervisibility with the the SDL, Coalpit Heath and Iron next nearest Acton. settlement edge?

Purpose 3: To assist in How representative is The current use is agricultural land 2 safeguarding the the site of the key which is physically and visually countryside from characteristics of the linked to the wider open agricultural encroachment countryside? land to the north and west.

What is the influence of The influence of urbanising features 2 urbanising features? can be seen across much of the SDL. The settlement edge along the eastern boundary has a strong urbanising effect with the visual influence of residential dwellings, roads, street lighting and commercial units. Furthermore, across parts of the SDL, the settlement edge of Coalpit Heath and Iron Acton is a discernible influence.

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NPPF Para 80 Green Application of Criteria Assessment Criteria Belt Test Score

Purpose 4: To preserve What is the nature of There is no proximity or intervisibility 1 the setting and special the spatial and visual with the historic core of a town and character of historic relationship between thus the area does not perform towns the site and the historic against this function. core of the nearest town?

Purpose 5: Is the land within the The SDL is entirely within the Green 2 To assist in urban Green Belt Belt. regeneration, by encouraging the recycling of derelict and other urban land

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Plans

Plan EDP 1 Strategic Development Area Locations (edp3485_d051a 23 May 2019 WG/FM)

Plan EDP 2 Environmental Planning Context (edp3485_d004c 23 May 2019 WG/FM)

Plan EDP 3 Landscape Character and Features (edp3485_d010c 23 May 2019 AL/WG)

Plan EDP 4 Topography Plan (edp3485_d001a 20 May 2019 WG/FM)

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