Peter Brett Associates (If Applicable)

South Gloucestershire Council New Local Plan Site Submission Form

GUIDANCE ON COMPLETING THIS FORM

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

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

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

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

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

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

Please enter the relevant Site Reference number from www.southglos.gov.uk/callforsites Has this site previously been Yes / No PSP039/SGJSP10018/SG000091 submitted?

If the site has already been submitted, how does the information provided in this form change the information you have previously provided to us?

This site now includes additional land to the north east, some of which has already been submitted to you, and it confirms that the whole site is available, achievable and suitable for development.

1 2. YOUR DETAILS Name Joanna Lee

Company/Organisation Peter Brett Associates (if applicable)

Address 10 Queen Square, Bristol, BS1 4NT

Telephone 0117 3327840

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

If acting on behalf of Tim Baker Landowner / developer Strategic Land Partnerships please provide client name Greendale Court and address details: Clyst St Mary Exeter EX5 1AW

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

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

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

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

2 3. SITE DETAILS

Site Address (including Land to the rear of Park Farm postcode where applicable) Barry Road Oldland Common Bristol, BS30 6QX

Site Area (Hectares)(if known) 25ha

Current land use(s) Arable Land

Adjacent land use(s) Variety of agricultural, residential, employment and recreation

Relevant planning history (if known) Planning applications PK/09/5056/O refused 19 October 2009 PK10/0484/O refused 10 June 2010

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

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

USE Capacity (number of units) and indication of possible residential tenures, types and housing for different groups Residential Yes/No Up to 650 units, with a mix of house sizes, tenures and elderly accommodation

USE Floorspace (m2) / number of floors/pitches / notes Office, research & development, Yes/No light industrial (B1) General industrial (B2) / Yes/No warehousing (B8) Sports / leisure (please specify) Yes/No Retail Yes/No

Gypsy and Travellers / Yes/No Travelling Showpeople sites

Other (please specify) Yes/No

Additional notes about potential uses: 3 5. SITE SUITABLITY ISSUES

Question Further details including details of further studies undertaken / mitigation proposed Does the site have any physical Yes/No constraints (e.g. topography, access, severe slope, vegetation cover etc.)?

Is the site subject to flooding? Yes/No

Is the site affected by ‘bad neighbour’ Yes/No Some overhead electricity lines cross the east of the uses (e.g. power lines, railway lines, site major highways, heavy industry)?

Is there a possibility that the site is Yes/No contaminated?

Can satisfactory vehicular access to the Yes/No As shown by plan submitted as part of the planning site be achieved? application

Has the Highways Agency been Yes / No Previously as part of application PK10/0484/O consulted?

Is the site subject to any other key Yes/No constraints?

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

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

Please provide any other relevant information relating to site suitability issues:

Mains sewerage, electricity, telecommunications, and gas are all available in the highway corridor that the site has frontage with and all have sufficient capacity to serve the scale of development proposed

4 6. SITE AVAILABILITY ISSUES

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

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

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

Is the site owned by a developer or is the YES owner willing to sell?

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

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

200 450

Do you have any information to support when the site will come forward and its phasing? Please consider suitability, achievability and constraints.

7. SITE ACHIEVABILITY ISSUES

Question Comments/further details Are there any known significant abnormal Yes/No Two new vehicular access points from development costs (e.g. contamination Barry Road. remediation, demolition, access etc.)? If yes, please specify. Does the site require significant new Yes/No infrastructure investment to be suitable for development? If yes, please specify. Are there any issues that may influence the Yes/No economic viability, delivery rates or timing of the development? If yes, please specify. Has a viability assessment / financial Yes/No appraisal of the scheme been undertaken?

5 Have any design work studies been Yes/No Ecological Report, Aboricultural Report, undertaken? Archaeological desk based study and evaluation, Flood Risk Assessment, Noise Assessment, contamination study, transport assessment report and heritage strategy – which were all submitted as part of the applications. 8. ADDITIONAL COMMENTS

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

The site is located on the south eastern built up edge of Bristol and is located approximately 9km from the City centre. Access to the site is gained from the A4175 which links the A420 with the A431 via Oldland Common. The site is well connected to Bristol City Centre. There is good access to alternative means of travel such as the cycle and bus network with a range of bus services and the Bristol / Bath cycle path within five minute walk of the site. Connections to local and national rail services can be found at Keynsham Railway Station which lies approximately 3km from the site.

St Anne’s C of E Primary School is located approximately 150 metres to the west of the site, on School Road. The local secondary school, The Sir Bernard Lovell School, is located within 800 metres walking distance to the north of the site. Oldland Common local centre is located approximately 300 metres north of the site and provides a range of local shops and services. Included within Oldland Common’s local centre are: • Doctors surgery • Veterinary surgery • Dentists • Post office • Pharmacy • Mini-supermarket • 2 Public houses • Fish and Chip shop • Chinese takeaway

Keeping new development close to the existing city edge with a band of closely related development is a potentially very efficient way of developing and one which will maximise the use of infrastructure as well as making new opportunities within the extension available to existing residents.

The site at Oldland Common lies adjacent to the periphery of Oldland Common/North Common and is contained by the strong Oldland ridgeline. Oldland Ridge is a strong landscape feature that provides a very clear threshold between town and country, protecting the Golden Valley and the AONB to the east from the visual influence of the city. The ridge also contributes to the setting of Bristol and, at the southern end, contains the city in distant views from the western edge of Bath. It is a landscape that is highly sensitive to change due to its exposed nature and development upon it would impact on the character of the landscape beyond and the setting of the AONB. It is considered to be ‘Fundamental’ to Green Belt. The containment of the Oldland Common site provided by the Oldland Ridge would ensure that development would not have an impact on the Green Belt beyond. As such it offers potential for removal from the Green Belt.

Topography is a particularly limiting factor to in the consideration of options for urban expansion on the eastern periphery of the city. However, the site lies at the foot and on the lowest slopes of the Oldland Ridge. It is influenced substantially by the intrusion of the existing urban edge and has a semi-rural character. If development is limited to below the 50 and 55 m. contour (which would include the majority of the site) this would ensure that development could: • relate well to this edge • be almost entirely obscured by existing development in views from elevated locations to the west • retain the function of the ridge and its upper slopes which provide important separation between the city and open countryside beyond, and containment when viewed from that countryside and the Cotswold escarpment/AONB • avoid any perception of encroachment or unconstrained growth (‘sprawl’), due to containment • retain the green backdrop that the slopes and ridge provide in this locality.

Almost all of the land within the site lies within lower lying land at the base of the Oldland Ridge, between 42 and 50 m. AOD. The southernmost field rises gently up to just over 60 m. AOD (this is some 29 m. lower than

6 the ridge to the east). Views to the east are wholly contained by the Oldland Ridge and, from within the site, there are no visual connections to the Golden Valley and Cotswold escarpment beyond.

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

7 D o c u m e n t P a t h Z \ P r o j e c t s \ 4 0 1 2 7 \ 0 2 m x d \ 4 0 1 2 7 O d a n d C o m m o n A 4 s t e o c a t o n P a n m x d

0 1 12 500 000 @ A4 500 0 1 75 000 @ A4 2 km km

proposed sites

PSP039 / SGJSP10018 / SG000091

0 1 7 500 @ A3 250 m

East Fringe, Oldland Common 13/02/2017 Location Plan Serv ce Layer Cred ts Source Esr D g ta G obe GeoEye Earthstar Drawn DRL Geograph cs CNES/A rbus DS USDA USGS AeroGR D GN and the G S User Commun ty Checked JL F gure 1 Rev A

The South Gloucestershire Local Plan

Pre Commencement Prospectus Consultation Representations on behalf of: Strategic Land Partnership

On behalf of Strategic Land Partnership

Project Ref: 40127| Rev: AA | Date: February 2017

Office Address: 10 Queen Square, Bristol, BS1 4NT T: +44 (0)117 332 7840 E: [email protected]

SLP Representations New South Gloucestershire Local Plan Consultation

Contents

1 Introduction ...... 1 1.1 General ...... 1 2 Duty to cooperate ...... 2 2.1 Working together ...... 2 3 Scope ...... 3 3.1 General scope ...... 3 3.2 Priorities and Vision ...... 4 3.3 Policies ...... 4 3.4 Community Infrastructure Levy ...... 5 3.5 Evidence base ...... 5 4 Call for Sites ...... 6 4.1 New and existing sites ...... 6 4.2 Urban living ...... 6 4.3 Rural Areas Sustainable Access profiles ...... 7 5 Timetable ...... 8 5.1 Progress ...... 8 6 Conclusion ...... 9 6.1 Summary ...... 9

Appendices

Appendix A Proposed sites – Oldland Common

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SLP Representations New South Gloucestershire Local Plan Consultation

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SLP Representations New South Gloucestershire Local Plan Consultation

1 Introduction

1.1 General

1.1.1 Peter Brett Associates (PBA) is pleased to submit comments on behalf of Strategic Land Partnership (SLP) in relation to the consultation on the prospectus issued by South Gloucestershire Council setting out its proposals for preparation of its New South Gloucestershire Local Plan (SGLP). These comments are structured on the same basis as the consultation document with the questions clearly answered. In addition, and where relevant, comments are also made on the topic papers and Sustainable Access Profiles Methodology, with particular relevance to our clients’ site at Barry Road, Oldland Common.

1.1.2 We welcome the attempt at positive planning and recognition of the need to get started with the plan review to ensure that it is consistent with, and prepared in parallel to, the West of England Joint Spatial Plan (JSP). While we make comments on the content of the prospectus documentation, it is important to address the relationship between this and the JSP because it is essential that the combination of documents must establish an appropriate spatial strategy for the long term, integrating new and existing development with necessary infrastructure to deliver required and worthwhile development.

1.1.3 A new Local Plan is necessary because the Core Strategy is clearly out of date in many respects, and indeed a review was specifically required by the Planning Inspector as a prerequisite of the Core Strategy being found sound.

1.1.4 The SGLP will cover the period 2018 – 2036, which is in line with the JSP timetable. It is essential and right that these timetables are aligned. It should be noted that the Council’s consultation document was prepared ahead of the Housing White Paper which sets the direction of travel for planning and will result in significant changes to be introduced through the NPPF and also guidance. It is essential that the New Local Plan adequately takes account of all the changes in planning policy as progress is made through the consultation process.

1.1.5 The Council is aiming to produce a draft version of the plan this year and while we support this emphasis on speedy plan making, it is essential that this plan accords with and reflects the JSP, and properly addresses the issues raised. It is somewhat surprising, although very much welcome, that the Council now feel able to bring forward non-strategic sites to address housing need, having just said at the Policies, Sites and Places DPD hearings that they are not in a position to do this. While the Council is right to progress as fast as possible, it is essential that they follow the JSP process and adequately address all the matters raised by the Examination into that plan. This will be particularly important in relation to any challenges to it, in the form of objection and any changes that may be required. Further comments on the timetable are included in section 5.

1.1.6 The Council is right to progress this new plan as soon as possible. It is essential that an up to date plan, which is comprehensive in scope and deliverable, is put in place. This will set out the detailed policy framework to implement the strategic targets and broad locations from the JSP, identify and allocate sites to address local growth needs in the rural area and provide detail on its form, scale, access and quantum. It is essential that the whole range of issues and needs that exist within South Gloucestershire is properly catered for and included within the SGLP.

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2 Duty to cooperate

2.1 Working together

2.1.1 The document raises the question (Q1) of what strategic matters and priorities should be engaged upon. Our view is that the key strategic issues will largely be dealt with through the JSP, which will set the key development needs and strategic priorities. The issues that remain to be addressed through the SGLP will be more local issues, but these will still need proper cooperation, especially where they relate to the allocation of sites to meet local need. This is particularly an issue around the East Fringe where it is essential to ensure that the cross boundary functional relationships with Bristol are properly considered.

2.1.2 It is surprising that the Council has not included reference to the Green Belt as a key issue which needs strategic cooperation and agreement with neighbours, stakeholders and developers. This was recognised as a key issue at the Policies, Sites and Places DPD hearings. Any Green Belt assessment work that is to be carried out to inform the identification and allocation of sites will need to be firmly grounded within the remit of the strategic Green Belt assessment that has already been undertaken. The methodology used will need to be consistent across the West of England to ensure that constant decision making is undertaken on a reliable basis. This should be consulted on at an early stage and agreement reached on the way this will be applied in the identification of sites and settlement boundary changes.

2.1.3 The Council has previously placed considerable reliance on Neighbourhood Plans to meet local needs and identify sites. As demonstrated at the Policies, Sites and Places DPD hearings this approach has failed to deliver sites and a different approach is now required. It is now necessary that the Council to take difficult decisions and allocate sufficient and deliverable sites in a wide variety of locations across its area to meet the local needs of communities. This will require cooperation with all local communities and not just representatives which want no change to the status quo.

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3 Scope

3.1 General scope

3.1.1 Since the Council published their prospectus document the Housing White Paper has been issued which requires authorities to be far more proactive in delivering the housing that is required, will test them on whether this delivery is being achieved and specifically identifies the importance of meeting the local need for elderly accommodation.

3.1.2 An important role for the JSP is to establish the amount of development, both for employment and all types of housing to be provided and it is essential that the SGLP takes on board these matters, reflects the most recent evidence and is up to date at any time. Consequently, it is essential for the SGLP to identify development opportunities and allocate strategic and non- strategic sites to meet the whole range of identified needs in full. The implications of the spatial strategy for policies and places needs to be examined properly. This is an essential role of the Plan and one which should cater properly for all types of need, especially disabled and elderly, as set out in White Paper. In addition, the Council must properly seek to plan positively for communities to grow and prosper and allocate development sites to meet these local needs. This has been a failure of planning in South Gloucestershire so far, because it was ignored in the Core Strategy and delegated to second tier plans, which have either not materialised, or have been adjusted in scope to exclude the vital role of housing sites in supporting places and communities. The Scope as set out in the consultation document does not properly prioritise the importance of identifying and meeting the local needs of individual communities, which is a key role of this plan.

3.1.3 The Council recognise the national policy imperative to address the housing and affordability crisis, and we support this objective. However, this needs to be translated from a vision into action. We would like to see a much firmer commitment to delivering housing to meet local needs. While the Government is currently consulting on a delivery test and implementing other measures to increase and speed up housing delivery, the Council should commit to taking action locally to increase affordable housing to meet local needs and to deliver housing to meet the needs of elderly, disabled and other specific user groups within the community providing support for thriving towns and villages, as well as communities on the edge of Bristol.

3.1.4 It is also critical for the plans in combination to deal properly with the issue of how any shortfall in the five year supply of housing land in the plan area as a whole, or in any part of the plan area is dealt with in other parts of the plan area.

3.1.5 Green Belt is a sensitive, ill understood and inadequately addressed issue in the West of England, as in most places, and raises particular issues over the respective roles of the ‘strategic’ and ‘local’ parts of the development plan being created. The JSP is currently flawed in not adequately changing the general extent of the Green Belt, removing strategic development sites and providing for ‘safeguarded land’ as well as establishing new boundaries, despite acknowledging at paragraph 42 if the November 2016 consultation that “it is not possible to sustainably accommodate all the identified growth needs entirely outside the Green Belt”. There is a clear requirement to use the Green Belt as the most sustainable location to meet future needs and this should be addressed properly by both the JSP and the SGLP. It should be noted that comments have been made to the JSP by WPL seeking the positive plan led approach to the Green Belt as the most sustainable way to meet the growth required.

3.1.6 The JSP November 2016 topic paper on the ‘Formulation of the Emerging Spatial Strategy’ states at paragraph 19 that “the West of England Authorities have come to the conclusion that the exceptional circumstances for altering the Green Belt are demonstrated because of the overwhelming benefits of locating as much of the development as possible in the most

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sustainable locations”. It is accepted that there is strong evidence that consideration needs to be given to Green Belt locations and specifically to consider locations in close proximity and well related to existing urban centre. Consequently, it is recognised that these exceptional circumstances exist. Therefore, we would expect that the SGLP will consider Green Belt sites which are in sustainable locations.

3.2 Priorities and Vision

3.2.1 In terms of the key priorities and vision set out within Topic Paper 1 the following comments are made in answer to questions 2 and 3:

 The rural area should be divided into separate parts, reflecting its different character and relationships. This approach would integrate with the ambition to include detailed visions for each part of the district as set out in paragraph 10 of Topic Paper 1.

 Not enough is being done for the communities of East Bristol which are surrounded by Green Belt to ensure that they get the development they require to provide for the local needs that exist, to support their local facilities and employment requirements and delivery a positive agenda for growth and ensuring they don’t stagnate purely because of the outdated restrictive policy approach set by an arbitrary Green Belt boundary.

 Once again the approach taken by the Council seems to be to concentrate their energy and focus on the places where it is a priority to direct and stimulate change and growth. While this is important, it is fundamental that this new Plan recognises the needs of the whole district particularly the communities and areas that have not been the focus of previous growth. This means more emphasis given to the fringes of East Bristol where it is essential to ensure affordable housing, employment opportunities and local schools and facilities which are retained and supported within their localities. This is acknowledged by the JSP November 2016 consultation commentary on Oldland Common.

3.3 Policies

3.3.1 Comments on Topic Paper 2 and answers to Q4, 5 and 6 are set out below:

 It is eminently sensible to use and combine policies where they are still up to date and relevant. However, it is important that policies are not just rolled forward but rather tested for their usefulness and purpose. Some policies will not be required due to the importance of not repeating the NPPF.

 We support the proposals for the structure of the plan to contain a part 1 with strategic policies and a part 2 with development management policies.

 We are pleased to see that site allocations and safeguarding is specifically envisaged as a policy area to be included. It is important that safeguarded land is properly identified and excluded from the Green Belt to ensure flexibility for meeting the longer term needs of communities which are constrained by this policy.

 We welcome the inclusion of a new policy dealing with housing for older people. This should be based on up to date evidence and should identify and respond to local needs identified within the individual local communities.

 In addition, it is suggested that the plan is made more user friendly by utilising interactive mapping, and other digital technology both in the consultation and engagement processes but also in the way it is ultimately presented. This is a specific objective of the Housing White Paper and should be addressed early in the process.

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3.4 Community Infrastructure Levy

3.4.1 Changes to CIL are not going to be announced until the Autumn budget and as such this will need to be considered as the plan progresses to ensure that the SGLP properly includes the most up to date and relevant position in relation to CIL.

3.5 Evidence base

3.5.1 A baseline set of evidence is essential for a proper, appropriate and robust position to be established. Local evidence is required to establish the local housing needs for affordable units and for specific age groups particularly in relation to supporting local communities and providing for housing that is directly required and will contribute to the sustainable development and retention of their facilities.

3.5.2 Local evidence on the Green Belt will be a fundamental element of the work. This has been discussed above and will need to be subject to consultation on the methodology and use a consistent approach across the West of England.

3.5.3 We note that there is no mention of a local Infrastructure Delivery Plan or Housing Implementation Strategy which will be an essential part of the evidence for the plan and its delivery.

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4 Call for Sites

4.1 New and existing sites

4.1.1 SLP have responded regularly to the call for sites process that the Council has undertaken most recently for the JSP process last year. The site at Barry Road, Oldland Common are suitable for development and should be included within the plan. The site is suitable, available and achievable and provide land to meet the development needs of these communities.

4.1.2 We have checked the register on the new Council website and provide the following update. The specific online forms have also been completed for the site and submitted to the call for sites process. For the avoidance of doubt the sites promoted are set out on the plans attached at Appendix A. Comments are made on the sites which are already identified on the Council’s website using the Council’s reference numbers:

 PSP039/SGJSP10018 and SG000091 – sites at Oldland Common – it is confirmed that this site is suitable, available and achievable. The site has been amalgamated into a single site with some additional land and further deliverability information is included in the call for sites form and plan which is submitted.

4.1.3 The land at Odland Common is immediately on the edge of Bristol and development would effectively be a continuation and consolidation of the established neighbourhood of Oldland Common, itself part of a pattern of development connecting the whole of Bristol. It is a good example of a site that is in a sustainable location, can be released from Green Belt with very limited conflict with the purposes of Green Belt, has few environmental or other impediments and can readily contribute to housing delivery. The JSP Towards the Emerging Spatial Strategy Document November 2016 recognises that this area may have some potential for some growth to support local services.

4.1.4 Oldland Common local centre already provides a range of local shops and services and there is a Primary School and Secondary School in very close proximity to the site. Transport issues are frequently raised by the planning authority and others in seeking to prevent development needs being met on the eastern edge of the city. Oldland Common however has been the subject of a planning application previously and on this occasion the heads of terms of a s106 agreement were established with agreed measures that enabled the highway authority to raise no objection to the proposed development. Consequently, the land shown on the plan at Appendix A is promoted for development and should be allocated within the SGLP because its release will have no significant impact on the integrity of the Bristol-Bath Green Belt.

4.2 Urban living

4.2.1 Paragraph 5.9 on ‘Urban Living’ implies that transport connections/interchanges and hubs are only applicable to the urban areas. It is essential that the rural areas and the opportunities for transport improvements are properly included in consideration of whether there is any catalyst which could provide the transformational change in locations to sustainably support provision of services to enable surrounding communities to flourish.

4.2.2 The East Bristol fringe at Oldland Common provides the opportunity for improvement and housing led regeneration to improve how it performs as a place and help facilitate investment and redevelopment to maximise the use of this area and ensure it meets its economic and social potential. Consequently, it is suggested that the East Bristol fringe is added to the list of areas at 5.10.

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4.3 Rural Areas Sustainable Access profiles

4.3.1 The following comments are made on the ‘Methodology’ and as such constitute the response to Q8 and Q9:

4.3.2 These profile are based on 2011 Census information. While this is the only available information it should be recognised that this is now quite out of date, and every effort should be made to ensure up to date figures are used where these are available.

4.3.3 While the location of major employers is included this should recognise that a major employer in the rural area is likely to be far smaller and an additional category should be included to map these rural employment opportunities. This needs to be addressed properly in the methodology and if necessary an appendix should be provided which properly considers the cross boundary issues and opportunities for some communities.

4.3.4 The use of 2 miles is described by the methodology as the statutory walking distance to a primary school, however, this does not seem to reflect the true nature of how far people will walk to schools, especially primary schools. This distance appears to be entirely out of line with the distance used to walk to a library and is even more than the distance used for walking to major employers, which would seem illogical.

4.3.5 We recognise the limitation of the walking and cycling analysis data and suggest that this should be able to use GIS mapping tools to identify actual walking and cycling routes and distances rather than standard ‘as the crow flies’’ information.

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5 Timetable

5.1 Progress

5.1.1 The Council is right to start the plan now and ensure that it is prepared in conjunction with, and consecutively to the JSP, rather than waiting for the JSP to be made before getting the review underway. However, it is important that the timetable recognises that there may be changes required to the JSP and that this will need to be factored into the preparation of the SGLP. The approach should be one that fully reflects the JSP, taking forward positive planning for the area by complementing the JSP in scope and content rather than inhibiting its implementation.

5.1.2 It is essential that the development plan is kept up to date and is a dynamic tool for implementing needed change. Consequently, it is crucial that the plan is not submitted until the Inspector has reported on the JSP and that there is time built into the programme to ensure that the Core Strategy Review can be updated and respond to any concerns or modifications that arise through the JSP process. It is noted that considerable objection has already been made to the emerging spatial strategy including by ourselves.

5.1.3 The programme is appropriate and is properly aligned with the JSP. However, it does not include any contingency or flexibility to deal with delays to the JSP programme or examination findings. If changes occur this will need to be properly factored into the programme and adjustments made to deal with issues as they arise. Recognition of this approach would be sensible and make clear that this plan is dependent on, and directly aligned with, the JSP.

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6 Conclusion

6.1 Summary

6.1.1 SLP welcome the commitment to progress the preparation of the New South Gloucestershire Local Plan. This should be in place as soon as possible after the JSP is adopted. It is equally important that the Local Plan should be fully reflective of the JSP, taking the planning for the area forward by complementing the JSP in its scope and content rather than inhibiting its implementation in any way, and adding to the ability of the development plan to be kept up to date and to be a dynamic tool for implementing needed change.

6.1.2 This will mean a full and proper consideration of sites to meet the strategic and local needs of the communities within South Gloucestershire. Consequently, the sites identified previously at Oldland Common are suitable, available and achievable for the sustainable development of housing, and should be allocated within the New South Gloucestershire Local Plan.

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Appendix A Proposed sites – Oldland Common

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D o c u m e n t P a t h Z \ P r o j e c t s \ 4 0 1 2 7 \ 0 2 m x d \ 4 0 1 2 7 O d a n d C o m m o n A 4 s t e o c a t o n P a n m x d

0 1 12 500 000 @ A4 500 0 1 75 000 @ A4 2 km km

proposed sites

PSP039 / SGJSP10018 / SG000091

0 1 7 500 @ A3 250 m