Phase 3 draft planning policies

Climate Change Mitigation, Adaptation and Resilience

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

This is a new policy topic.

Purpose

Our climate is changing, and we need to both limit this change, by reducing emissions (mitigation), and adapt to the changes to the climate that are already going to occur (adaptation and resilience).

The council declared a Climate Emergency on 17th July 2019, which included a pledge to provide the leadership to enable South Gloucestershire to become carbon neutral by 2030, and also to enable our communities to achieve 100% clean energy across all sectors.

The risks from a changing climate are wide and include flooding, coastal change, extreme temperatures and the growth in pests and diseases new to the UK. However, there can be wider social, environmental and economic benefits from tackling climate change, for example, by providing adaptation measures such as trees that provide shading and also benefit nature.

Through the new Local Plan, we can guide and set requirements for new development to ensure that climate change is addressed wherever possible.

This policy is a key principle behind the emerging development strategy of the Local Plan, and it is also reinforced and supported throughout the plan by more detailed policies which cover specific issues such as design, energy management, green infrastructure, sustainable transport and renewable energy.

Policy wording

To contribute to local and national climate targets development proposals must demonstrate how they will mitigate greenhouse gas emissions and be designed to be resilient to the escalating effects of a changing climate.

Climate mitigation

All development proposals must:

  • minimise heating and cooling energy demand and associated emissions of greenhouse gas emissions, using layout, orientation and built form and net zero energy (or Passivhaus equivalent) fabric efficiency standards (Draft Policy: Energy Management in New Development)
  • maximise on-site renewable energy generation with the objective of meeting annual energy demand (Draft Policy: Energy Management in New Development)
  • ensure design which is sufficiently flexible and adaptable to enable changes of use or layout and facilitate future refurbishment
  • enable forms of development which encourage walking, cycling, wheeling and the use of public transport instead of journeys by private car
  • utilise materials (Draft policy: Embodied Carbon) and other natural and limited resources, such as water and land, sustainably. The development of new homes will be expected to achieve a water efficiency standard of no more than 110 litres per person per day

Climate adaptation

The climate we experience at present is not the climate we will experience in the future. For all development, an adaptation assessment should be submitted that demonstrates how the proposal has been designed to be resilient to the effects of a changing climate.

The assessment will be appropriate to the scale or type of development and lead to a more informed design.

All new development of a sufficient scale will be expected to include the following within their adaptation assessments:

Assessment of climate risk

Adaptation strategies should assess the proposal’s location and surroundings, within the current and future climate to inform the design. This assessment should:

  • identify how the climate will change over the lifetime of the development including but not limited to:
    – increased temperature (includes extremes of temperature)
    – changes in rainfall (in particular if this leads to drought or flooding)
    – tidal changes (including impact of rising sea levels)

  • identify how these changes may impact the proposed development, taking into account:
    – the location of the development and any site specific current and future risks
    – whether the development could exacerbate climate change risks in the surrounding area
    – the vulnerability of the development’s present and future occupants, if known, (as specific additional considerations or measures may be appropriate to different groups)
    – any other risks, hazards or opportunities that come out of the climate risk assessment

Informed design

The assessment will feed into the design of the development, and should be used to inform as appropriate:

  • layout, form, massing and orientation of the development
  • external hard and soft landscape design
  • building design and building integrated measures
  • use of green and blue infrastructure

General principles

The adaptation assessment should include:

  • technical modelling of overheating in current and future climate change scenarios and demonstration of how this modelling has informed the design so that overheating risk is minimised, and any residual risk is overcome ensuring that cooling needs are met sustainably in accordance with policy Energy Management in New Development
  • demonstration of how water will be used efficiently
  • demonstration of how nature-based solutions such as green and blue (and brown) infrastructure has been incorporated and are a primary consideration in design adaptation measures as they can offer multiple co-benefits
  • demonstration of how green infrastructure has been used to provide cooler external spaces for use in periods of hot weather
  • a description of how the development responds to other significant climate risks identified
  • demonstration of how the responses to climate change avoid or minimise increases to energy use and CO2 emissions

BREEAM

For major non-residential development, a BREEAM assessment will be required. A BREEAM ‘Excellent’ Rating will be expected.

For residential or mixed-use development consisting of more than 100 residential units, a BREEAM Communities scoping assessment should be provided to determine whether a partial or full BREEAM Communities Assessment is required. Where a full BREEAM Communities Assessment is applicable an ‘Excellent’ rating will be required.

Supporting text

Our climate is changing, and we need to both limit this change, by reducing emissions (mitigation), and adapt to the changes to the climate that are already going to occur (adaptation and resilience).

By incorporating mitigation, adaptation and resilience measures into development we will reduce emissions and help to meet local and national climate change targets.

The impacts of a changing climate will be broad and are projected to include impact such as increases in average and peak summer temperatures, more frequent, intense and longer lasting extreme heat events, changes in rainfall patterns and intensity, and an increase in the frequency and intensity of storms.

Incorporating adaptation, resilience and mitigation into development proposals will require the consideration of a wide range of issues, both those explicitly set out in this policy; and other policies as set out within the plan including:

There are also a range of relevant supplementary planning documents, available on our website, that provide more detail and information on topics as well as technical guidance notes on how to adhere to policy.

Climate change mitigation

Mitigation primarily means minimising greenhouse gas emissions from proposals. Emissions come from the transportation and materials used in the construction process, as well as the emissions from the operation and use of the development throughout its expected lifetime.

Draft Policy 2: Energy Management in New Development; and draft Policy 3: Embodied Carbon contain detailed policy requirements to reduce emissions from new development.

The location of new development is an important consideration in terms of reducing emissions and this has been incorporated into the overall development strategy within the local plan. There will also be emissions from the travel movements of users and requiring active travel measures to be incorporated in new development, will help to mitigate emissions.

Flexible design can for example reduce the need to demolish and rebuild and therefore reduce lifetime emissions from development.

Water should be conserved, as it is a limited natural resource, but there are also emissions associated with its provision and removal from new development and this policy aims to limit these emissions by ensuring water is conserved to an appropriate level.

Climate change adaptation and resilience

The climate we experience at present is not the climate we will experience in the future. To ensure development needs is suitable for its lifetime use, appropriate adaptation and resilience measures should be incorporated in all development.

Adaptation and resilience assessment

Assessment of climate risk

  • the UK Climate Projections.
  • for residential development, the Good Homes Alliance Early-Stage Overheating Risk Tool checklist
  • National Adaptation Strategy 3

Informed design

General criteria

Overheating:

For all development except householder the risk of overheating within the building should be assessed using the following methodologies or future replacement standards:

  • CIBSE TM52 for non-residential buildings
  • CIBSE TM59 for residential buildings

The important component of the above methodology is that is undertakes an assessment of the development against future weather files, as well as current weather files. This is key to understanding the lifetime climate risks of the development in relation to overheating.

There are a wide range of adaptation measures that could be implanted in relation to overheating:

Site level methods for adapting to or reducing the risk of overheating include:

  • Outdoor heat refuge areas that are shaded, sited to take advantage of airflow and have seating
  • Internal heat refuge rooms which are well insulated and ventilated, free from heat generating plant or other sources of heat gain, shaded and sited appropriately within the development to avoid excessive solar gain
  • Increased vegetation, including green/brown roofs and vegetated walls
  • Design to enable airflow through buildings, such as enabling cross ventilation and through the use of automatic louvres, and secure ventilation openings/louvres
  • Open water and fountains
  • Shaded public spaces and footpaths
  • External finishes that are designed to avoid heat absorption; and
  • Site layout and orientation to maximise micro-climactic cooling and interconnection of greenspaces and corridors.

Building level adaptations for mitigating the risk of overheating could relate to:

  • ceiling heights and glazing areas informed by orientation and room uses
  • purge ventilation for the removal of heat
  • exposed thermal mass with automated night purging
  • openable windows and secure ventilation openings
  • solar shading, deep window reveals and overhangs
  • thermal insulation coupled with adequate ventilation
  • services design, and
  • where the use of active cooling is unavoidable, the use of low or zero carbon systems and systems where reject heat from cooling can be recovered or stored on a seasonal basis

By incorporating sustainable cooling into the design process, buildings will be better equipped to manage their cooling needs and to adapt to the changing climate they will experience over their lifetime, whilst not relying on other more carbon and energy intensive means, such as air conditioning systems.

Water:

Low summer rainfall and fluctuations due to greater climate instability could lead to water shortages, a decrease in water quality and impacts on the natural environment due to inflows into watercourses having less of a dilution effect on pollutants.

Methods for conserving water resources could include:

  • reduction in water demand, for example through low water-use planting and efficient fixtures and fittings
  • increased use of reclaimed and recycled water, and
  • use of sustainable drainage systems to collect and store water

Green and blue Infrastructure:

Green and blue infrastructure can provide direct adaptation benefits, such as shading, but also has benefits beyond helping places adapt to a changing climate such as providing green and active travel routes. When designing green/blue infrastructure for climate adaptation, the provision for a wide range of multifunctional benefits will be encouraged.

BREEAM

BREEAM is method of assessing, rating and certifying the sustainability of buildings and other built environment projects that has been in use for a significant length of time at many local authorities. Assessing major projects against BREEAM will ensure that new development thoroughly considers the wide range of issues in sustainable design and construction against a certified method, where the assessments must be completed by a licensed assessor.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Energy Management in New Development

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Policies, Sites and Places Plan Policy PSP6 – Onsite renewable and low carbon energy

Purpose

This policy concerns operational energy use in new development; that is the energy used to heat, cool, light and run appliances and services in buildings. The purpose is to ensure that new buildings are designed, and constructed in a way that minimises operational energy use, and greenhouse gases emissions that come from this use, and to maximise the amount of energy that can be generated from building-integrated renewable energy technologies.

The UK Government has committed to achieving ‘net zero’ emissions by 2050 and is aiming to fully decarbonise electricity generation by 2035. Net zero means reducing UK emissions by a 100% (from 1990 levels), and that any emissions that cannot be eliminated, are offset by activities that remove an equivalent amount of greenhouse gases from the atmosphere. For heating it means replacing gas and oil boilers with renewable heating, such as air or ground source heat pumps or connection to a heat network supplied by heat generated renewably or by waste heat from industrial or commercial processes.

As more of our electricity is generated renewably, buildings that use electricity rather than gas or oil for heating will have lower carbon dioxide emissions – even if they are very inefficient and waste a lot of energy – because the electricity itself is low carbon. The fall in the carbon intensity of electricity is a welcome and crucial step to getting to net zero. But it means that in isolation carbon dioxide emissions, may not tell us how energy efficient or sustainable a building is. For this reason, the performance targets for new buildings in this policy, are based on their annual energy use, and annual energy generation, rather than annual carbon dioxide emissions.

The policy sets two energy efficiency targets, one for space heating and one for total energy use. Total energy use which is also known as Energy Use Intensity (EUI), is the total amount of energy used in a building as recorded by the energy meter. To allow for size differences, targets are expressed per square meter of floor area and refer to the energy used in one year. EUI targets for non-residential buildings are adjusted according to building type, to reflect different levels of use.

The policy also requires new buildings to achieve ‘net zero energy’ on an annual basis. A net zero energy building will generate as much energy at is uses in one year from renewable sources, such as solar photovoltaic (PV) panels, attached to the building.

Policy wording

Operational Carbon

Energy Hierarchy for new development

All residential and non-residential development proposals will be expected to:

  • a) Calculate and report predicted energy use intensity (EUI) using an operational energy model; and
  • b) Minimise energy demand for heating, cooling, hot water, lighting and power through building and site-level measures starting from a ‘fabric first’ approach, and including demand response and storage measures to support energy system flexibility; and then
  • c) Meet its remaining heat/cooling demand sustainably as set out below; and then
  • d) Maximise on-site renewable energy generation to achieve an annual net zero energy balance; and then if necessary;
  • e) Meet any outstanding reduction in residual energy use through energy offsetting.

Proposals should demonstrate, utilising the information set out within their Energy and Sustainability Statement, how these policy requirements will be met, including the specific standards as set out below.

Specific standards for development

  • f) All proposals for residential and non-residential development must achieve the following standard:
    A space heating demand equal to or less than 15kWh/m2/yr; and
  • g) All proposals for residential development should also achieve a total energy use equal to or less than 35 kWh/m2/yr (EUI): and
  • h) All proposals for non-residential development should also achieve a total energy use aligned with the latest industry benchmarks for that use (set these out here or in the supporting text, UK Net Zero Carbon Buildings Standard should be publishing in the Autumn):

Where it is clearly demonstrated that it is not technically feasible for the development to generate sufficient on-site renewable energy equivalent to at least its own annual energy consumption.

  • i) the development proposal should provide on-site renewable energy of 105 kWh/m²fp/year1 and then:
  • j) the remaining operational energy needs of the development should be met by offsetting measures as set out below.

Energy offsetting

Where the above requirements for energy use cannot be met by on-site measures alone, any remaining energy use will be met by offsetting measures such as:

  • entering into an appropriate legal agreement to provide a financial contribution to South Gloucestershire Council
  • agreeing acceptable directly linked or near-site provision.

Currently, the financial contribution for offsetting is set at a rate of £90 per MWh for a period of 30 years. This rate is index linked and will be adjusted annually.

Development involving existing buildings

Where work is being undertaken on existing buildings and it is not feasible for the full residential and non-residential targets above to be met, the Energy and Sustainability Statement should explain why (for example the building is listed) and show that energy demand has been reduced to the lowest practical level using energy efficiency measures, heating/cooling systems have been selected in accordance with the heating/cooling hierarchy and that on-site renewable energy will be installed where feasible.

Passivhaus

An alternative route to compliance is through the certified PassivHaus Plus or higher standard. Where development is proposed to be built and certified to this standard, the specific policy requirements above relating to energy use, on-site renewables and energy offsetting will not need to be met.

Where this route to policy compliance is pursued, a full Energy assessment as part of the Energy and Sustainability Statement will not be required. It will be sufficient to submit the technical information required to demonstrate that the PassivHaus plus standard can be, achieved and for the Energy assessment to demonstrate that residual heating/cooling demand for the development has been met sustainably, as set out below.

Demand and system flexibility

Proposals for major development should demonstrate how smart and flexible technologies to support the balancing of energy supply and demand over the course of the day and the year have been incorporated, taking account of the latest best practice and guidance.

Measures may include, among others:

  • minimising energy demand at peak times;
  • allocating space for internal and/or external battery energy storage; and
  • provision for vehicle-to-grid charging.

Heating and cooling systems

Development will be expected to demonstrate through its Energy and Sustainability Statement that heating systems have been selected in accordance with the following hierarchy:

  • where feasible connection to an existing classified heat network or a new classified heat network from the point of occupation; and then
  • elsewhere, employing individual renewable heat or communal renewable heat which is fossil fuel free.

Proposals should seek to eliminate the need for cooling systems throughout the lifecycle of the development and, in instances where cooling systems are required, minimise their capacity and energy consumption in accordance with the following steps:

  • minimise the amount of heat entering buildings during warmer months through orientation, form, shading, surface finish, glazing design and insulation; then
  • minimise internal heat generation through energy efficient design and specification; then
  • maximise the use of passive cooling and ventilation to manage internal temperatures; and then
  • having minimised the need for cooling, meet any residual requirement through energy efficient mechanical ventilation and active cooling systems.

Monitoring

To minimise the performance gap between design aspiration and completed development in addition to the submission of the pre-built estimates of energy performance as outlined above, the Energy and Sustainability Statement must include details of assured performance arrangements.

As a minimum, prior to each building being occupied, the submission of updated, accurate and verified ‘as built’ calculations of energy performance should be provided.

Such a submission should also be provided to the first occupier including a Non-Technical Summary of such estimate.

Supporting text

Energy use in development

Almost half of UK greenhouse gas emissions are linked to the construction and operation of its built environment, and 90% of a building’s environmental impact is defined by early design decisions. So ensuring new development is net zero carbon is a key part of tackling the climate emergency and reaching net zero. This policy concerns operational energy use in new development; that is the energy used to heat, cool, light and run appliances and services in buildings, and the emissions that result from these uses. The embodied carbon in a building is covered in a separate policy. Together, operational emissions and embodied carbon emissions make up the whole life emissions of the building.

Energy assessments

Proposals for development should be accompanied by an Energy assessment as part of the Energy and Sustainability Statement submitted with the planning application. The Energy Assessment should describe how the operational energy needs of the building or buildings will be met, and how the space heating and energy use intensity (EUI) targets set in this policy will be achieved.

The EUI and space heating demand should be calculated using the gross internal floor area (GIA) and expressed as the energy consumption per square meter of floor area (kWh/m2). The EUI is the total energy use of the building as recorded at the consumption meter so includes regulated and unregulated energy use, however, it does not include charging of electric vehicles.

Currently, South Gloucestershire Council’s preferred approach to modelling operational energy use is for developers to use CIBSE TM54: Evaluating Operational Energy Use at Design Stage, or for residential development the Passivhaus Planning Package (PHPP). Any change to this will be detailed in further guidance issued by the council.

Space heating and hot water

The Energy Assessment should demonstrate how the maximum space heating demand target of 15 kWh/m²/year has been achieved.

The Energy assessment should follow the energy hierarchy and demonstrate how:

  • the demand for heating, cooling, hot water, auxiliary energy, lighting and unregulated energy consumption will be minimised through energy efficiency measures; then
  • the remaining heat/cooling demand will be met sustainably; then
  • on-site renewable energy generation will achieve net zero energy; then
  • any remaining outstanding reduction in residual emissions will be achieved through accepted means of energy offsetting.

Heating and cooling systems

Renewable sources of heating and power include ground, water and air source heat pumps, geothermal heat and heat and cooling from former mine workings, solar photovoltaics, solar thermal, biomass and wind (large and small scale).

South Gloucestershire has an extensive network of former mine workings with potential to provide heating and cooling to new and existing developments. For developments of 100 units or more the Energy Assessment should consider whether flooded, former mine workings could serve as a source of heating and cooling delivered via a heat network.

The policy approach to heating systems intentionally excludes non-renewable electrical space and water heating, and in all cases individual gas boilers. In the case of certified Passivhaus Plus schemes non-renewable electric heating (also known as direct electric heating or panel heaters) may be specified).

Where gas boilers or gas CHP is proposed as a temporary or interim source of heat for a heat network or communal heating system, a full justification will be required within the Energy Assessment explaining why non-fossil gas alternatives are not feasible, and how and when gas will be removed.

When considering proposals for heat pumps and active cooling systems, the global warming potential of the refrigerants used will also need to be taken into account in a manner consistent with Draft Policy: Embodied Carbon.

Hydrogen

Given the low overall efficiency when using hydrogen for heating, its limited availability, and a potential need to use it to decarbonise specific processes such as steel making and heavy long-distance road freight, we do not expect to see hydrogen being used as a main fuel for heating and cooling. However, where hydrogen constitutes all or part of the energy mix for a development’s heating or cooling strategy, all CO2 and methane emissions arising from the production of the hydrogen should be accounted for within calculations submitted in the Energy Assessment. A 20-year integrated time period, and a global warming potential of no less than 86 should be used when calculating the impact of methane emissions.

Embodied Carbon

Where usability issues (as described in Part O of the Building Regulations), such as noise, are stated as the reason that a development requires active cooling, then all reasonably practicable passive means of minimising cooling requirements should be applied first and reasons why they were not sufficient provided.

Biomass

Here, biomass refers to the burning of biomass (including wood chip, wood pellets, logs and straw) for the production of heat, or heat and electricity (CHP). Given concerns about particulate emissions from burning biomass we do not expect developers to specify biomass as the primary source of fuel for heating or the production of heating and power. Where biomass is specified as a primary or secondary source of heat a full description and justification should be provided in the Energy Assessment. This should also explain clearly how concerns about particulate emissions have been addressed, describe the fuel source and how this will deliver genuine reductions in carbon dioxide emissions for the lifetime of the scheme.

Heat networks

Renewable, low carbon heating and cooling can also be distributed via heat networks. These can supply single buildings, groups of buildings or large parts of a community and can utilise heat from one or more sources. Heat networks are key to providing a renewable or low-carbon source of heating and cooling to existing buildings as well as new development. The connection of new development to a heat network can support the expansion of the network and connection of a wider number of existing buildings.

South Gloucestershire Council is actively considering how heat networks can be used to provide affordable and very low carbon heat to existing communities and new development in the district. This includes the potential use of reject heat from industrial and commercial processes and former mine workings as a source of both heating and cooling. The development of heat networks is central to the council’s strategy for delivering affordable, secure and zero carbon heat across the district.

‘Classified heat networks’ refer to heat networks that meet specific requirements, and which may be developed by third parties, or South Gloucestershire Council.

These requirements are:

  • compliance with the appropriate technical standards (presently the CIBSE Code of Practice), and regulatory requirements set by Ofgem or another regulator.
  • the heat and cooling supplied by the network is derived from renewable/low carbon sources or it can be demonstrated that the network is on a clear timeline and technology pathway towards decarbonising the heat provided by the energy centre.
  • the heat network provider offers heating and/or cooling services at a fair and affordable price to the consumer in accordance with minimum standards set by the regulator or industry best practice (such as standards defined by the Heat Trust or Ofgem).
  • the heat network provider publishes an annual report on the performance and carbon content of the network.
  • residual emissions from low-carbon sources are offset by approved measures.

The creation of new heat networks should be considered in the case of proposals that would provide more than 100 homes or 10,000m² floorspace. In these cases, a feasibility study should be undertaken to establish whether a new heat network could be established.

Where heat networks are proposed as part of development, they will be expected to meet the requirements for a ‘classified’ heat network as set out above.

When calculating the Energy Use Intensity (EUI) of a development connecting to a heat network, an Energy Conversion Factor will be applied to take account of the efficiency of the network and energy centre. Energy Conversion Factors for classified heat networks will be provided by South Gloucestershire Council, or the heat network operator, and updated to reflect changes in the operation of the heat network.

Where new heat networks are proposed as part of an existing network, the Energy Conversion Factor shall be calculated by the applicant.

Net zero energy and on-site renewable energy generation

A net zero energy building will generate as much energy from renewable sources at is uses in one year.

The Energy Assessment should set out what renewable heating, renewable cooling and renewable power generation measures have been considered and which will be incorporated into the proposed specification. The Assessment should show that minimum targets for electricity generation from PV have been met and that the scheme will generate sufficient energy to achieve net zero energy. Where this cannot be achieved full justification should be provided.

Energy offsetting

Energy offsetting should only be considered as a ‘last resort’ where it is not possible to generate sufficient energy on-site to meet annual energy demand. We expect this to be achievable in most instances.

The fund will be established and administered by the council and will be collected via Section 106 agreements. Funds will be allocated to low carbon projects within South Gloucestershire, where additionality is clear, such as renewable energy schemes, and retrofitting existing housing stock, with a focus on lower income households.

The contribution is calculated at £90 per MWh per year for 30 years. The £90 will be index linked and therefore increase annually. Further information will be set out via South Gloucestershire’s website.

Passivhaus

In recognition of the high sustainability standards required to achieve a ‘Certified Passivhaus Plus’ scheme, this may be used as an alternative route to policy compliance.

Passivhaus is an international energy standard for buildings. It sets stringent standards on energy consumption for heating and overall energy demand, and also sets design requirements to control the quality of the internal environment.

Proposals seeking to follow the PassivHaus Plus route to compliance set out in this policy will need to be accompanied by full PassivHaus Planning Package outputs demonstrating that the PassivHaus Plus standard can be achieved.

Prior to commencement, a ‘pre-construction compliance check’ completed by a PassivHaus certifier will be required and secured by condition.

Upon completion, a Quality Approved PassivHaus Plus certificate for each dwelling/building will be required.

Minimising the performance gap and delivering modelled performance

There is significant evidence showing that the energy performance of buildings once constructed is worse than when they were designed. The difference between anticipated and actual performance is known as the performance gap.

Addressing the performance gap is a key part of ensuring the built environment is net zero in practice.

Implementing a quality regime from design, through to construction and handover has been shown to reduce the performance gap.

Relevant regimes include:

BSRIA Soft Landings;

Government Soft Landings;

NABERS Design for Performance;

Passivhaus;

Actions set out in BREEAM credits Ene 01 Reduction of Energy Use and Carbon Emission, Man 04 Commissioning and Handover and Man 05 Aftercare; and

Actions set out in the Home Quality Mark issues 9 Quality Assurance and 11 Customer Experience.

Monitoring, verifying and reporting on the actual energy performance of buildings in-use can enhance the construction industry’s knowledge on the performance gap and help to identify issues with new buildings that then can be addressed by building owners.

Reporting on energy performance will become increasingly common whether through Government initiatives such as the proposed national performance-based policy framework for rating the energy and carbon performance of commercial and industrial buildings or voluntary initiatives such as the Built Environment Carbon Database.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Embodied Carbon draft policy

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

This is a new policy.

Purpose

This policy concerns embodied carbon emissions in new residential and non-residential buildings. Embodied carbon refers to the emissions of carbon dioxide, and other greenhouse gases, produced by the extraction, processing, manufacture and transport of materials used in a building, and emissions from the energy and water used in its production, assembly, and construction. It also includes any emissions from leakage of refrigerants in heat pumps, where the refrigerant is a greenhouse gas.

The UK Government has committed to achieving ‘net zero’ emissions by 2050. This requires a 100% reduction in emissions (from 1990 levels), and any emissions that cannot be eliminated, to be offset by activities that remove an equivalent amount of greenhouse gases from the atmosphere. For buildings ‘net zero’ includes the emissions from operational energy use (energy used for heating, cooling, lighting and appliances), and the embodied carbon emissions. Together, these make up the ‘whole life carbon’ emissions of a building. As emissions from operational energy use in new buildings reduce, due to higher efficiency standards and renewable heating, embodied carbon emissions make-up a larger proportion of whole life carbon emissions. For this reason, South Gloucestershire Council is introducing polices on operational energy use and emissions, and this policy on embodied carbon emissions.

Embodied carbon emissions will be different for each building and will depend on the embodied carbon of each kilogram of material specified, and the total quantity of that material in the final building. The embodied carbon of a new building can be reduced by selecting materials which have low embodied carbon and by reducing the quantity of materials with high embodied carbon. Where existing buildings are being demolished and replaced, the embodied carbon of the new building will be reduced if materials from the old building can be reclaimed and reused, so this policy is designed to encourage the reuse and recycling of materials, as well as the efficient use of resources.

The policy sets targets for embodied carbon in new residential and non-residential buildings. To allow for different sizes of buildings, targets are expressed per square meter of floor area. The need for stronger construction, and therefore higher embodied carbon, in taller buildings is also allowed for in the targets. Developers are required to calculate the embodied carbon emissions of a residential or non-residential building using a nationally recognised assessment methodology. Emissions of greenhouse gases other than carbon dioxide are converted into carbon dioxide equivalent emissions (CO2e) to allow a single target to be set for each development type.

Policy wording

Embodied carbon – general principles

Proposals will be expected to show how development will minimise its embodied carbon. In doing so, development should:

  • Prioritise the renovation or retrofit of existing structures, as part of an efficient use of land,
  • Minimise the quantity of materials required to meet the building’s functional requirements;
  • Select high quality materials and systems which:
    • Have low embodied carbon;
    • Minimise the need for replacement over the lifetime of the development;
    • Can be reused, recycled and disposed of sustainably at end of life;
    • Are compatible with other policies in the plan in particular Draft Policy: Energy Management in New Development in relation to overheating; and
  • Ensure that waste reduction is designed in from project inception to completion, including consideration of the use of standardised components, modular build, and reuse of secondary products and materials
  • Ensure that new buildings are flexible and adaptable to future uses, reducing the need for future redevelopment.

Proposals should set out how these issues will be addressed in the Energy and Sustainability Statement.

Embodied carbon – major applications

Proposals for major development will be required to include an embodied carbon assessment, submitted as part of the Energy and Sustainability Statement using a nationally recognised embodied carbon assessment methodology, and demonstrate actions taken to reduce whole life-cycle carbon emissions.

Major new development will be expected to achieve the following targets as a minimum for upfront embodied carbon (construction phase),

  • Residential (4 storeys or fewer) – <625 kgCO2e/m²
  • Residential (5 storeys or greater) – <800 kgCO2e/m²
  • Major non-residential schemes – <970 kgCO2e/m²

Where it is not viable to meet these targets for embodied carbon, a full justification will be required as part of the embodied carbon assessment within the Energy and Sustainability Statement.

Any shortfall against the embodied carbon targets will be offset through a financial contribution towards council approved renewable energy, low-carbon energy and energy efficiency schemes elsewhere in South Gloucestershire. The value of a tonne of CO2e is tied to the ‘high’ scenario in the Valuation of Energy Use and Greenhouse Gas supplementary guidance to the Treasury’s Green Book (£373 at the time of publication).

Refrigerants

In all new development with fixed building services that include a refrigerant, the global warming potential (GWP) of the refrigerants should be minimised, by designing systems to have the lowest possible refrigerant volume/charge and specifying heat pumps (including VRFs) that use refrigerants with the lowest global warming potential available.

Refrigerants and their associated impacts should be included and accounted for within the embodied carbon assessment conducted by the developer using an approved methodology as set out in the guidance.

Materials

The materials used in development should use and manage resources as efficiently as possible. As well as having low embodied carbon within the materials, the wider environmental impacts arising from their sourcing, manufacture, construction, and end of life demolition and disposal must be considered within the Energy and Sustainability Statement.

Development should avoid the use of tropical hardwoods, unless reclaimed, reused or recycled, and provide full justification showing that there are no feasible alternatives if virgin tropical hardwoods are specified.

Demolitions, waste and recycling

Ensuring that materials are reused and recycled whenever possible, and that waste is minimised, is an important consideration in reducing the overall embodied carbon of the proposal and this policy as a whole is designed to ensure this.

Where proposals do include demolition, they should aim to maximise the amount of material recovered for reuse and recycling, either on-site or at another site.

Supporting text

Embodied Carbon

Embodied carbon refers to the emissions of carbon dioxide, and other greenhouse gases, produced by the extraction, processing, manufacture and transport of materials used in a building, and emissions from the energy and water used in its production, assembly, and construction. It also includes any emissions from leakage of refrigerants in heat pumps, where the refrigerant is a greenhouse gas.

Emissions are produced at all stages of the development process with the majority of embodied carbon emissions being ‘upfront’, meaning that they are produced at the beginning of the development cycle. It is these ‘upfront’ embodied carbon emissions that this policy aims to reduce by requiring developers to calculate embodied carbon and meet targets according to the type of development.

It is important that measures to reduce embodied carbon emissions are considered and implemented alongside Draft Policies: Climate Mitigation, Adaptation and Resilience, and Energy Management in New Development. If these policies are not considered together there is a risk that buildings become more vulnerable to overheating (by for example through the selection of materials with a lower thermal mass and a reduction in air permeability) and that demand for active cooling will increase, which will in-turn lead to higher operational energy demand and lifetime emissions.

Embodied carbon – general principles

This policy is intended to reduce the embodied carbon in new buildings and to encourage the reuse and recycling of materials, as well as the efficient use of resources. Embodied carbon emissions will be different for each building and will depend on the embodied carbon of each kilogram of material specified, and the total quantity of that material used to construct the building. Embodied carbon can be reduced by selecting materials which have low embodied carbon and by reducing the quantity of materials with high embodied carbon.

Embodied carbon assessments

Embodied carbon assessments should set out the actions that will be taken to reduce embodied carbon emissions of new development. Calculation of embodied carbon emissions should be made using a council-approved methodology.

The scope should include life-cycle stages A1-A5 which address product sourcing and the construction stage, as defined in BS EN 15978 Sustainability of Construction Works, and each element should be reported on both separately and in aggregate.

Where the embodied carbon assessment indicates that it is not feasible to meet the targets in this policy, full justification will be required, and assessments will be evaluated for technical quality and to determine whether appropriate actions have been taken to reduce embodied carbon throughout the project’s development.

Whilst the policy only sets targets for the upfront embodied carbon (stages A1 – A5), an assessment of stages B1-B5 and C1-C4 should be provided where this information is available. As evidence supporting targets for other whole-life stages becomes available developers may be required to provide an embodied carbon assessment of stages B1-B5 and C1-C4. Please refer to the policy guidance for up-to-date information on this.

The carbon assessment will not be expected to include an assessment of external works outside the building footprint.

Refrigerants

Many refrigerants used in fixed building services like heating and cooling systems are potent greenhouse gases with the potential to make significant contributions to global warming if released to the atmosphere. As heat pumps become much more common in new and existing buildings it is important to consider the climate impact of the refrigerants they use.

Many of the refrigerants commonly used in heat pumps have a global warming potential (GWP) many times higher than that of CO2. For reference, R32 has a global warming potential 675 times that of CO2 and R410A is a greenhouse gas 2,088 times more potent than CO2. This means that releasing 1kg of R32 into the atmosphere is equivalent to releasing 675kg of CO2, and releasing a kilogram of R410A is equivalent to releasing over two tonnes of CO2.

The global warming impact of refrigerants should be minimised by:

  • Minimising the volume and mass of refrigerants used in a development by:
    • Minimising or eliminating the need for heating or cooling systems through energy efficient design.
    • Avoiding the use of systems that have high refrigerant charge per kW capacity, such as systems that use refrigerant as the distribution medium to emitters.
  • Minimising the potential impact of the refrigerant used by selecting equipment that uses refrigerants with the lowest available global warming potential.
  • Minimising the risk of refrigerant leakage through:
    • Avoiding the use of systems that use refrigerant as a distribution medium, particularly where refrigerant is distributed to emitters.
    • Specifying leak detection and monitoring systems in accordance with industry best practice.
    • Regular maintenance.
    • Ensuring that installation, maintenance, decommissioning and disposal of all appliances using refrigerants is only ever undertaken by suitably qualified persons.

In major developments where heat pumps, (including VRF and VRV units) are proposed, the global warming impact from refrigerant leakage should be included within the embodied carbon calculation using an approved methodology (please refer to detailed technical guidance for approved methodologies).

Where heat pump systems use refrigerants that have a global warming potential (GWP) of 750 or greater are specified, full justification will be required including numerical whole-life carbon modelling.

Materials

Tropical forests have an essential role to play in providing eco-system services, biodiversity and climate change mitigation and adaptation but are vulnerable to deforestation, degradation and the direct impacts of climate change.

Research has found that even ‘sustainable harvesting’ of timber can lead to the degradation of forest ecosystems. For these reasons developers should not specify any tropical hardwoods in new development, unless these are shown to be reclaimed, reused or recycled.

Demolitions, waste and recycling

Ensuring that materials are reused and recycled whenever possible, and that waste is minimised at all stages of development, including the final end of life stage, is an important consideration in reducing the embodied carbon and other environmental impacts of new development.

Construction stage waste should be considered as part of the Construction Environmental Management Plan (CEMP) for the site, which should set out how materials can be reused and recycled as much as possible.

Though, it is not possible to control how a building will be dismantled, demolished and disposed of until it reaches the end of its life, in specifying and designing new buildings developers should consider how to minimise the use of materials that cannot be easily reused and recycled, and materials which may toxic and difficult to safely dispose of.

As Embodied Carbon Assessments become more comprehensive, and we get more information on whole life cycle assessments, we expect the understanding of the end-of-life stages of development, and minimising waste to become clearer.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Renewable and Low Carbon Energy Systems

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Core Strategy Policy CS3 – Renewable and low carbon energy generation

Partial replacement of CS4 – Renewable or low carbon district heat networks

Purpose

South Gloucestershire has significant opportunities to increase renewable energy generation and facilitate development that enables a smarter and more flexible energy system.

Accelerating the transition to zero carbon heat and a zero-carbon electricity system is essential to addressing the climate emergency. It can also bring wider environmental, public health and economic benefits, and improve the security of our energy supply.

Policy support is therefore provided to development proposals which generate energy renewably or recover waste heat; and the infrastructure that goes alongside this. Specific support is set out for wind as required by national guidance.

Policy wording

All proposals for standalone renewable energy types and associated infrastructure

  1. Proposals for the generation of renewable energy and associated infrastructure; or the recovery of waste heat or cooling; and proposals that support the transition to a smart, flexible, and zero carbon energy system will be supported in the context of sustainable development and climate change.
  2. In assessing proposals, the following will be considered:
    • a. The contribution of the proposals, in light of the council’s pledge to be carbon neutral by 2030 and national carbon reduction targets 1, to cutting greenhouse gas emissions and decarbonising our energy system;
    • b. The contribution that will be made to meeting the objectives of the Green Infrastructure Strategy, and to achieving a sustained increase in biodiversity (Supplementary Planning Document (SPD) – Biodiversity and Planning: guidance for new developments) for the duration of the scheme;
    • c. Where a proposal is linked to an existing use, is located in close proximity to that use and is designed to displace otherwise imported energy to that use; this will be considered an additional benefit; and
    • d. Local amenity and other relevant issues.
  3. Opportunities for the co-location of renewable energy generation with energy demand, will be encouraged.
  4. Proposals for wind and solar PV farms to re-power at the end of their operational life will be permitted, as long as the turbines and/or solar panels are replaced with new equipment of either the same or larger installed capacity, and subject to compliance with statutory, site-specific, and other constraints.
  5. There are appropriate plans and a mechanism in place for the removal of the technology on cessation of generation, and restoration of the site to its original or an acceptable alternative use. Site restoration where the ecological value is further enhanced will be considered favourably.
    In addition to the above, the following will be considered for the specific technologies outlined:
  6. Wind Energy
    • a. The policies maps show areas where onshore wind energy development proposals might be suitable subject to the assessment of the other criteria as set out in the policy
    • b. It is also considered that large new development sites or safeguarded employment sites may be suitable in principle for wind energy development subject to the assessment of the other criteria as set out in the policy
    • c. Community support must be evidenced for all scales of wind energy
  7. Safeguarded locations for wind energy
    • a. Areas safeguarded for standalone wind energy development are defined on the Policies Map.
    • b. Proposals for development that is not associated with wind energy within these areas will only be acceptable where:
      • i. it can be demonstrated that they would not prejudice or interfere with the operation of any installed, permitted, proposed or future potential wind energy installation or its enabling infrastructure; or
      • ii. the use proposed would be temporary, and would not restrict the potential future use of the site (or adjacent land) to be developed for wind energy; or
      • iii. It can be demonstrated that due to permanent technical generation related constraints, there is no reasonable likelihood of a wind energy installation ever coming forward on or within reasonable proximity to the application site or that an exception should be made based on substantial public benefits arising from the proposal.
  8. Ground mounted Solar
    Proposals for ground mounted solar developments should avoid being sited on the best and most versatile agricultural land unless significant benefits can be shown which would outweigh the temporary loss of the land.
  9. Mine-water
    Mine water energy development proposals will be supported as part of the transition to a low carbon economy where:
    • a. There would not be a significant adverse impact on the water regime and water quality impacts are assessed and mitigated; and
    • b. The visual impact of associated buildings and equipment is minimised.
  10. Biomass
    • a. Biomass should be of a scale and type which is appropriate to the location and should not have a detrimental impact on air quality.
    • b. Applications utilising virgin plant feedstocks will need to robustly demonstrate that the feedstock will be sourced sustainably;
  11. Energy balancing including storage and generation
    • a. Proposals for new energy generation or storage installations/ proposals, that support the transition to a smart energy system are considered an integral part of a low carbon energy system and will be considered favourably:
      • i. Proposals for, or including, any new balancing, storage or generation plants must demonstrate that the lowest emission technology available has been utilised;
      • ii. Applications for energy plant utilising virgin plant feedstocks will need to robustly demonstrate that the feedstock will be sourced sustainably;
      • iii. Large scale energy development (over 1MW) should look to include energy storage technology alongside the energy deployment.
    • b. Fossil fuel-based energy installations in which greenhouse gas emissions are not captured and sequestered, are not considered compatible with a net zero energy system and as such will only be acceptable where no other alternative is available and for a temporary period. Full justification should be set out in the Energy and Sustainability Statement.

Supporting text

Increasing renewable and low carbon energy generation and storage within the local authority area is an important means of delivering both our local, and national government, carbon dioxide emissions reductions targets.

Renewable energy generation covers a range of technologies such as solar photovoltaic generation, wind and tidal power, and heat produced by air, ground, or water source heat pumps. Low carbon energy supplies include waste heat and coolth (cooling) from commercial and industrial processes and heat or coolth (cooling) recovered within or from buildings, neighbourhoods and developments.

Renewable Energy Resource Assessment for South Gloucestershire (RERAS)

To ensure we had the technical information to underpin this policy, we undertook a study to develop an evidence base for the potential of renewable energy technologies in the district. The full Renewable Energy Resource Assessment for South Gloucestershire (RERAS) can be found on our website. A Landscape Sensitivity analysis was undertaken as part of this. The outputs from the RERAS have fed into the development of this policy.

General considerations

The National Planning Policy framework and associated guidance set out both general and technology specific considerations. For example cumulative impact on landscape or impact on local amenity, which need to be considered for all technologies; or shadow flicker which is specific for wind energy development. This policy does not aim to duplicate all of these, but they should be considered when determining planning applications.

This policy sets out additional considerations for all stand-alone renewable energy projects as well as specific considerations for wind energy, ground mounted solar, biomass and mine water heat. Proposals over 50MW, other than for battery storage, are considered Nationally Significant Infrastructure projects and are determined by the Planning Inspectorate with the local authority as a consultee.

Climate emergency

Accelerating the decarbonisation and decentralisation of the energy system in the UK is essential to mitigating climate change. Renewable energy generation will assist us in meeting our local and the national climate targets and this should be a consideration in determining planning applications.

Green Infrastructure and Biodiversity

Where designed appropriately renewable energy installations can offer opportunities to increase site biodiversity and help meet our green infrastructure objectives.

It is also important that installations are designed to enable this, for example, with solar panels, the specification of the panels in terms of height and cabling should be suitable to allow biodiversity measures such as wildflowers under panels. Therefore, consideration should be given at the planning application stage, including the use of suitable planning conditions, to ensure that this is enabled.

Location of energy and re-powering

Where renewable energy installations are being developed to specifically provide power to meet the needs of an existing development, in particular if they are privately connected, this can make efficient use of land and is considered a benefit. The same principle applies to locating heat users and heat producers in close proximity.

Re-powering existing turbines also making efficient use of land and existing resources and infrastructure.

Wind

The RERAS showed that the potential opportunities and areas where large scale wind installations can effectively operate on a commercial basis are limited within South Gloucestershire and these areas are proposed to be safeguarded.

The opportunity for smaller scale wind development (under 05.MW) is more widespread and as such these areas are not proposed to be safeguarded but form broad areas of search on the policies maps for further consideration. Turbine development within these areas should be assessed against the criteria as set out in the above policy and within the National Planning Policy Framework and associated guidance.

It is important to stress that both the safeguarded areas and the broad areas of search as set out on the Policies Map are only ‘potentially suitable’ for wind turbines: being within these locations does not mean that an application for a wind turbine or turbines would automatically be approved. All applications for wind turbines will be assessed against the detailed policy criteria set out in Draft Policy: Renewable and Low Carbon Energy Systems above, and all other relevant policies in this Local Plan, as well as policies in any relevant Neighbourhood Plan.

Whilst the RERAS primarily considers renewable technologies at a scale suited to a commercial developer, and this is how the different turbine sizes were set, the smaller scale wind turbine development areas are considered potentially suitable for turbines with a lower output than in the RERAS as might be the case for some community scale proposals.

As set out in the NPPF all wind development should have community support with the planning concerns of the community dealt with and it is important for commercial schemes to engage with local communities at an early stage in the development process.

Proposals for renewable energy, including wind, that are from the community energy sector, or include a significant element of community ownership, have additional benefits and considerations and as such community led schemes are subject to their own policy with specific considerations (see Draft Policy: Community Energy).

Solar

The ground mounted solar resource is widespread across the South Gloucestershire area and as such no specific safeguarding of areas is proposed. The maps define areas as potentially suitable but also allow the consideration of developments outside these areas where clear justification can be provided.

The RERAS set out a range of criteria to determine suitability of areas for solar development and these criteria should be considered when applications are put forward.

As the solar resource is widespread and best and most versatile agricultural land is limited, it is considered that it should be avoided unless justification is put forward.

Mine-water heat

South Gloucestershire has an extensive network of former mine workings. These were worked for the extraction of coal over a period of 150 years up to the 1920’s. Mine workings flood when no-longer used and this floodwater is warmed by natural geological processes. This provides a potential heat resource, that in combination with heat pumps, can supply heat networks delivering space heating and hot water. Mine water can also be used to provide cooling in new and existing buildings. If exploited this resource could significantly contribute to carbon dioxide targets within the district.

Biomass

The impact of biomass on air quality and virgin feedstocks should be assessed.

Energy balancing, including storage and generation

As renewable generation accounts for an increasing proportion of electricity generation, and fossil fuel generating plant such as coal and gas, are decommissioned, the requirement for grid balancing services is increasing. These are needed to ensure that energy supply always matches demand and to respond to inherent fluctuations in the output from wind and solar and variations in electricity demand.

Grid balancing will be achieved by measures including shifting demand peaks (such as winter evenings) through special energy tariffs, and the use of smart appliances including electric vehicles, and energy storage. Electric vehicles and storage can be charged with electricity when supply exceeds demand, and then supply electricity when demand exceeds supply.

Applications for grid balancing services align with the council’s climate declaration, however, applications for services using fossil fuels (e.g., gas turbines) are not encouraged and will need to provide a full justification for why this technology, rather than alternatives such as battery storage are proposed.

As set out in the RERAS study when storage is provided alongside large-scale generation it can provide direct balancing benefits storing excess energy when it is not needed by the grid. It also helps to make the best and most efficient use of storage technologies and the embodied energy within them. Therefore, for renewable applications over 1MW investigating storage options alongside renewable energy generation is encouraged by this policy.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Community Energy

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Core Strategy Policy CS3 – Renewable and low carbon energy generation

Purpose

Community developed energy schemes contribute towards carbon reduction and renewable energy generation targets, but they also offer wider benefits. They can bring greater awareness of energy and climate issues to communities and the money raised by renewables schemes can be utilised within the community for further energy saving measures. Some organisations also use the money raised from community energy for other wellbeing projects.

Communities themselves are becoming more aware and starting to look at how they can develop schemes.

This policy aims to specifically encourage schemes that directly benefit communities.

Policy wording

  1. Proposals for the development of community-led energy schemes or schemes that will demonstrably benefit a community will be considered favourably, subject to:
    • a. The majority of the benefit being directed to a local community, and:
    • b. A local community maintaining an enduring legal interest in the operation and governance of such proposals, and:
    • c. Robust and compelling evidence of broad community support for the proposal being provided.
  2. In the case of community energy proposals with the Cotswolds Area of Outstanding Natural Beauty, where community benefits are proposed to meet the ‘exceptional circumstances’ test; or, the Green Belt, where community benefits are proposed to meet the ‘very special circumstances’ test, an exception to policies of constraint will be considered favourably where, in addition to the above requirements, there are substantial and definable social, economic or environmental benefits for a local community that arise directly from the proposal.

Supporting text

Community developed energy schemes contribute towards carbon reduction and renewable energy generation targets, but they also offer wider benefits. They can bring wider awareness of energy and climate issues to communities and the money raised by renewables schemes can be utilised within the community for further energy saving measures. Some organisations also use the money raised from community energy for other wellbeing projects.

Communities themselves are becoming more aware and starting to look at how they can develop schemes. Draft Policy: Community Energy aims to specifically encourage schemes that directly benefit communities.

For flexibility, the policy does not set out specifically what is meant by a community-led scheme, but it is considered that it should be led by and directly meet the needs of the local community putting it forward and the majority of the benefit should be for the local community.

Communities are likely to be defined at Parish level, or a geographical area defined by a neighbourhood plan, and should have a suitable legal mechanism already in place defining the community group prior to submission of an application.

For example, the project could be part or fully owned by a local community group or social enterprise; local community members could have a significant governance stake in the project or organisation e.g. with voting rights, or a community could work alongside a commercial developer, ensuring the development is meeting the needs of the community.

It is considered that all communities should be able to benefit from, and bring forward, community led renewable energy schemes; as communities live within their local landscape and will be most impacted by both the benefits and impact of any scheme.

Where proposals are put forward in the designated landscapes of the AONB and Greenbelt or near heritage assets, a more significant level of benefit should be directly provided for a local community to show the scheme benefits outweigh any temporary landscape harm.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Affordable Homes (Strategic Policy)

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Core Strategy policy CS18 – Affordable Housing

Purpose

The council is committed to supporting people with the cost of living crisis and to ensure everyone has access to an affordable, decent, safe and sustainable home. The affordability of housing and providing a range of housing types for different stages of people’s life journeys, are key priorities for the council to ensure local people are not priced out of their communities, everyone can put down sustainable roots and have buy-in to the community they live in and call home.

Maximising the provision of Affordable Housing in South Gloucestershire to meet housing need to create sustainable, inclusive communities is a key way the council will achieve these objectives. While there is a marked increase in the older population, overall the greatest Affordable Housing need continues to be for family-sized homes and for this to be delivered as social rent.

The main source of new Affordable Homes is on sites for market housing through planning policy. The Affordable Homes delivered are primarily for social rent and shared ownership at lower equity shares that are affordable to people on local incomes.

In addition, the council will maximise opportunities to deliver Affordable Homes using grant funding or other forms of investment with preference for social rent. This will include 100% Affordable Housing schemes and additional Affordable Homes on market-led sites.

Acceptable development for relevant residential schemes will be expected to deliver as a minimum policy compliant levels of Affordable Housing to design and quality standards, as defined in National Planning Policy Framework 2021 (Annex 2) or any national policy that updates it.

The average need identified by the Local Housing Needs Assessment 2023 per year over the period 2025-2040 is 365 new Affordable Homes, equating to 27% of need for housing of all tenures (5,478 in total). This compares to a potential average annual housing supply of around 1366 homes (both market and Affordable) based on the South Gloucestershire Standard method figure (20,490 in total).

In addition to meeting the actual level of Affordable Housing need in full, the council’s aspiration is to reduce the number of households in the private rented sector relying on housing benefits to pay their housing costs by 25%, to return to the pre-pandemic level.

To meet the need (365 Affordable Homes pa) and also the councils aspiration, the Affordable Housing target in the Plan is set at 6,709, or 447 Affordable Homes per year, which is 33% of all new homes to be provided.

To secure overall provision of Affordable Housing at 33% of the total, the policy will require at least 35% to allow for sites that are ineligible to apply Affordable Housing policy or where there may be viability constraints. 35% is the minimum level to be provided to create sustainable, inclusive communities which offer choice and broaden opportunities for current and future residents. Allocated and windfall greenfield sites that have no significant infrastructure requirements or abnormal viability constraints are required to achieve 40% Affordable Housing.

The particular shortage of Affordable Housing in rural areas and the need to maintain and sustain rural communities is recognised by the council. Local communities will be encouraged and supported to play a greater role in shaping the future of their own areas, including the provision of Affordable Homes, using opportunities presented by Neighbourhood Planning. Policy CS19 sets out the council’s approach to rural exceptions.

The council will further explain its policy guidance on Affordable Housing by updating and replacing the current SPD and Technical Advice Notes.

Policy wording

  1. The overall objective of this policy is to first meet the need for Affordable Homes in full as demonstrated in the latest version of the South Gloucestershire Local Housing Needs Assessment. Secondly, to reduce the number of households in the private rented sector that rely on benefits to meet their housing costs to the pre-pandemic level. To achieve the two objectives, the policy aspiration is for 6,709 Affordable Homes or 447 per year.
  2. All new housing developments of 10 or more dwellings or 0.5 hectares (the lower of the two thresholds applies) are required to achieve without public subsidy a minimum of 35% on-site Affordable Housing, except in designated rural areas where the threshold will be 5 or more dwellings. Relevant greenfield sites with no significant infrastructure requirements or viability constraints are required to achieve 40% on-site Affordable Housing. Where this results in a ‘fraction’ of a dwelling, this should be rounded up to a whole dwelling.
  3. Affordable Housing will be maximised, and as well as meeting the overall quantum, it is expected that specific Affordable Housing tenure and unit types are provided to meet the housing need demonstrated in the latest version of the South Gloucestershire Local Housing Needs Assessment, and in rural areas, where appropriate, local housing needs surveys. The need is primarily for social rented homes and shared ownership at lower equity shares that are affordable to people on local incomes.
  4. To meet sustainability and community objectives, Affordable Housing should be provided on the application site. However, in exceptional circumstances and where it can be robustly justified, the council may accept off-site provision, or a financial contribution of broadly equivalent value in lieu of on-site provision.
  5. In exceptional circumstances a lower percentage may be agreed by the council if the developer demonstrates that the planning obligations impact the economic viability fundamentally and prevent the site from coming forward. In such cases, other types of funding should be sought to make up the shortfall, with preference for delivery of social rent. There will be a requirement throughout the build-out period for the viability of the development and the availability of public subsidy or other forms of investment to be periodically reviewed to identify whether a figure closer to the policy requirement can be achieved from the site.
  6. All Affordable Homes delivered under this policy must be let to eligible households and remain at an affordable price for future generations of eligible households. In the case of any sales of properties delivered under planning policy, the subsidy is to be recycled to provide alternative Affordable Housing in South Gloucestershire.
  7. All self-contained dwellings will be subject to this policy including where care and/or communal facilities are provided as part of the development (except Build to Rent where criterion 9 applies).
  8. Where it is proposed to either phase development, sub-divide sites or there is a reasonable prospect of adjoining land being developed for residential purposes, including where there are existing buildings on the site, the council will consider the whole land package and the total quantum of homes across that land package, to determine whether the scheme falls above the threshold set out in criterion 2 to require Affordable Housing. Applications will be refused if it is considered that the developer is artificially suppressing the quantum to avoid delivering Affordable Housing.
  9. Developers of Build to Rent housing will be required to provide on-site Affordable Private Rented homes without public subsidy with rents (including service charges) set at up to 80% of the market rent for an equivalent property, but not exceeding the relevant Local Housing Allowance (including rent increases). The council and the developer can agree to meet this requirement by other routes, preferably by providing other forms of Affordable Housing as defined in NPPF and/or a financial contribution.
  10. Where a site that is allocated as 100% self and custom-build delivery triggers the requirement for Affordable Housing, 35% of the self and custom-build homes must meet the definition of Affordable Housing in NPPF. The council may agree that the requirement can be met via other routes, such as a financial contribution.

Supporting text

Affordable Housing requirement

The council’s policy objective is to meet the identified need for Affordable Homes in full and to meet its target to reduce the number of households in the private rented sector relying on housing benefits to pay their housing costs by 25% to return to the pre-pandemic level.  

This policy requires at least 35% Affordable Housing at nil public subsidy, to meet council objectives to deliver sustainable and inclusive communities having regard to economic viability constraints. Sites of typologies that can reasonably be expected to deliver more than 35% because they do not carry a significant infrastructure burden or abnormal costs will be required to deliver 40% Affordable Housing.  

This is justified because all sites do not deliver the full policy requirement; some sites are under-threshold or affected by viability or Vacant Building Credit.  

It is a reasonable approach to require a minimum of 35% Affordable Housing across all sites to make up the shortfall as 35% is currently broadly viable across the District. It is a robust target, capable of being achieved in the medium to longer term.  

It is reasonable to expect that where sites can deliver a higher level of Affordable Housing, additional provision will be required. These sites are likely to be in rural areas, where there is a more competitive market and fewer new homes are delivered, resulting in a wider gap between incomes and house prices that makes affordability issues more acute.  

Where the requirement results in a fraction of a dwelling, this should be rounded up to a whole dwelling to ensure that Affordable Housing provision is maximized and no less than 35% is delivered.  

If it is agreed by the council that the policy requirement is not viable at nil public subsidy, a combination of other financial support such as grant funding must be sought to achieve the full requirement.  

Relevant housing sites

NPPF specifies that provision of Affordable Housing should be sought on major sites, defined as development where 10 or more homes will be provided or the site has an area of 0.5 hectares or more, and that a lower threshold of 5 units or fewer may be set in designated rural areas. In South Gloucestershire, the only designated rural area is the Cotswold Area of Outstanding Natural Beauty.  

The Affordable Homes policy applies to: 

  • all self-contained dwellings, regardless of Use Class. This includes specialist residential developments that also provide care and support and communal facilities such as a residents’ lounge or a restaurant, and non-campus-based student accommodation (criteria 1-8) 
  • mixed-use schemes (criteria 1-8) 
  • Build to Rent housing schemes at the lower percentage of 20% in line with NPPF (criteria 1,4,5,6, 9)  
  • Self and custom-build developments (criteria 1,4,5, 6,8,10)  

Where scheme proposals fall directly below the threshold for Affordable Housing, the density and unit types will be assessed by the council to identify whether the proposed quantum is being suppressed to avoid the Affordable Housing requirement. Any such applications will be refused. 

Types of Affordable Housing required

Affordable Housing must be provided to meet the need identified in the LHNA (or as updated by future housing needs assessments and in rural areas, where appropriate, to local housing needs surveys). This includes tenure types, unit mix and accessibility standards as well as the overall quantum.

In applying the Affordable Housing policy to specialist or supported housing, particular considerations may apply because of the nature of this accommodation; the council will advise if it is appropriate to provide the general size/ type mix of housing set out in the LHNA.

The definition of Affordable Housing is set out in the NPPF and includes:

  • Affordable Housing for Rent (including Social Rent, Affordable Rent and Affordable Private Rent
    • The greatest need in South Gloucestershire is for social rented housing. This is the council’s preferred rented tenure type.
    • If Affordable Rent is provided, the council will expect to agree rent levels that are appropriate to local incomes (not exceeding the relevant Local Housing Allowance) while achieving a policy compliant percentage of Affordable Housing
    • Build to Rent housing is defined in NPPF as ‘purpose-built housing that is typically 100% rented out’. Affordable Private Rented homes are provided within Build to Rent schemes as Affordable Housing, distributed throughout the development and physically indistinguishable from the market rent homes in terms of quality and size.
  • Affordable routes to home ownership (including shared ownership)
    • Shared Ownership is the council’s preferred Affordable Home Ownership tenure, with equity shares of 40% and residual rent of 1.5% to meet local incomes. Government guidance requires 25% of Affordable Housing on residential schemes of 10 homes or more (or where the site area is 0.5 hectares or greater) to be delivered as First Homes, however the council will seek shared ownership as it is more flexible, is affordable for a wider range of low-income households, enables buyers to acquire additional equity shares to reach full ownership and it is deliverable in a wider range of house types.  
  • Starter homes
  • Discounted market sale (including First Homes)
    • First Homes are a form of discounted sale housing (sold at a maximum of 70% of open market value) and fall within the definitions of Affordable Housing in the NPPF. Specific criteria and exemptions apply. All First Homes must comply with the Affordable Homes Policy and relevant Supplementary Planning Document. The council will monitor local house prices against incomes and may introduce a requirement for a larger % discount if the needs evidence supports it.

In 2023 we consider the tenure split should be 67% social rent and 33% shared ownership and this will be subject to review.

Site viability

Normally, the full policy requirement for Affordable Housing will be expected to be provided without public subsidy as it is currently broadly viable across the District. However, if the applicant demonstrates that exceptional circumstances justify the need for a viability assessment at the application stage, the council will consider the economic viability of individual developments. All viability assessments must be carried out following RICS guidance and will be independently verified by the council with the developer liable for reasonable costs incurred. All viability assessments must be made publicly available.

The council will expect the maximum level of Affordable Housing on each site to be provided, taking into account the economic viability of the site, likely costs, market conditions, the availability of public subsidy and the aim of achieving sustainable, inclusive communities.

Where developers have clearly demonstrated that full provision of Affordable Housing is not viable, and the council agrees, the applicant must actively seek and secure other forms of subsidy to demonstrate that every effort has been made to deliver the full policy requirement. The council will support an application for grant funding, or consider alternative financial support measures, to increase the Affordable Housing to the full policy requirement, with preference for social rent delivery to meet the greatest need.

The council will accept a lower amount of Affordable Housing only where it is demonstrated that other forms of subsidy are not available to deliver additional Affordable Housing to meet the full requirement. This is to ensure that Affordable Housing is maximised, but that sites that are not fully viable are not prevented from coming forward. On sites where the full requirement cannot be met, viability and the availability of public subsidy and other forms of investment must be reviewed throughout the build-out period. This is to ensure that all opportunities to maximise Affordable Housing have been taken.

On sites allocated solely for Affordable Housing, or where only Affordable Homes are proposed, there will be no requirement to deliver a percentage without public subsidy where the threshold is exceeded, providing that the proposed Affordable Housing meets identified need and complies with the requirements of the Affordable Housing Supplementary Planning Document.

Financial contributions

Financial contributions for Affordable Housing secured through planning policy as a last resort and receipts from the sale of any properties secured through planning policy will be used to meet the housing objectives set out in the Housing Strategy, for example:

  • To support unviable schemes
  • To increase the amount of Affordable Housing above the policy requirement
  • To increase the proportion of social rented homes
  • To increase the proportion of family-sized homes
  • To support specialist schemes for supported housing or older people.

Delivery

Affordable Housing will be delivered within the framework of this Local Plan and the council’s Housing Strategy and must reflect Government policy. Delivery is supported by more detailed guidance in the Supplementary Planning Document. Delivery will support the wider objective of creating sustainable, inclusive communities, infrastructure and growth. Affordable Housing will normally form part of the overall development, well integrated with and indistinguishable from market housing.

The precise details of quantities, type and mix of Affordable Housing on specific sites will be a matter for negotiation with the Housing Enabling team and Planning Officers.

The “pepperpotting” of Affordable Housing in small clusters within mixed tenure developments will be sought in accordance with the design guidance in the SPD.

First Homes on exception sites

The council will support proposals for First Homes Exception sites where it can be demonstrated that the need for such homes is not being met elsewhere in South Gloucestershire.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Sites for Gypsies and Travellers

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Policy CS21 – Gypsy and Traveller Accommodation

Purpose

South Gloucestershire is home to a significant population of gypsies and travellers who have been a long-established part of the community. The majority of gypsies and travellers who live in South Gloucestershire are Romany Gypsies and Irish Travellers who are protected ethnic minorities.

There has been a longstanding shortage of sites for these groups in South Gloucestershire. This policy is intended to meet this need, safeguard existing authorised sites for gypsy and traveller use and set out the updated criteria which will be used to determine all planning applications for new gypsy and traveller provision.

Policy wording

Sites for gypsies and travellers

Proposals for gypsy and traveller sites will be considered against the following essential criteria:

  1. Sites should have adequate provision for vehicular access, parking and manoeuvring;
  2. Sites should not have a significant impact on character and appearance which is unable to be mitigated by landscaping measures;
  3. Sites should be an acceptable level of amenity for site residents and any adjacent residential uses;
  4. Sites should not be located on land that is deemed unsuitable for general housing, such as land that is contaminated (and not capable of remediation), adjacent to refuse sites, landfill sites, heavy industry or electricity pylons.
    In addition, the following desirable criteria should be considered:
  5. Any opportunities for green infrastructure within the site design;
  6. Any opportunities for adequate play space for children.

Gypsy and traveller sites are as matter of principle acceptable in the open countryside. Due to the nature of South Gloucestershire no location should be excluded on the basis of distance to services.

Green Belt

Sites in the Green Belt will only be permitted on the basis of very special circumstances in line with national planning policy.

The following matters are relevant in establishing the existence of very special circumstances and may be capable of clearly outweighing the harm to the Green Belt:

  • The highly constrained nature of South Gloucestershire; and
  • The longstanding unmet need for sites.

Safeguarded sites

Existing authorised* land for accommodation by gypsies and travellers will be safeguarded at the following sites:

  • Hill View, Badminton Road, Nibley*
  • Swan Lane, Winterbourne (3 sites)*
  • Frampton Park, (Cog Mill), Bristol Road, Frampton Cotterell*
  • Elm Farm, Westerleigh Road, Westerleigh*
  • Green Orchards, Berwick Lane, Easter Compton*
  • Shortwood Yard, Shortwood Hill, Pucklechurch*
  • Greengate Yard, Shortwood Hill, Pucklechurch*
  • Parkfield Road, Pucklechurch (2 sites)*
  • Siston Lane, Siston (2 sites)*
  • Orchard Farm, Pomphrey Hill, Mangotsfield*
  • Westerleigh Road, Mangotsfield
  • Burton Road, Tormarton (2 sites)
  • Appletrees, New Street, Charfield
  • Bank Road, Pilning*
  • Henfield Paddock, Henfield Road, Coalpit Heath*
  • Cottage View, Gloucester Road, Almondsbury*
  • 56 Ram Hill, Coalpit Heath*
  • Moor Paddock, Westerleigh Road, Pucklechurch*
  • Tall Trees, Over Lane, Almondsbury
  • Bridge View, Westerleigh Road, Westerleigh*
  • Meadow View, Shortwood Road, Pucklechurch*
  • Highwood Park, Highwood Road, Patchway
  • Northwood Park, Old Gloucester Road, Winterbourne*
  • Homefield, Hall End Lane, Wickwar
  • 1 Dibden Lane, Emersons Green
  • Land at Giddy End, High Lane, Winterbourne*
  • The Meadows, Parkfield, Pucklechurch*
  • Leechpool Dairy Farm, Tanhouse Lane, Yate
  • Caravan Near Aust Services, Sandy Lane, Aust*
  • Tytherington Road Nursery, Tytherington Road Thornbury
  • Land at Oldbury Lane
  • Land at Shortwood Rd, Pucklechurch*
  • Land off Hall End Lane
  • Land at Bristol Rd, Frampton Cotterell *
  • Land at Northwick Rd, Pilning*
  • Land at Berwick Grange, Easter Compton*
  • Norley Lane, Tormarton
  • Land off Northwick Road, Pilning*
  • Land North of Lime Kiln Court, Tytherington*
  • Land Off Bury Hill Hambrook*
  • Land at Northwick Road, Pilning*
  • Field north and east of Crossing Cottage East of Railway Latteridge Road Iron Acton*
  • Land South Of The Northwick Road And Bank Road Junction, Pilning*
  • Land off Henfield Road, Coalpit Heath*

Existing sites within the Green Belt (shown with *) are shown on the proposals map and are removed from the Green Belt.

New sites proposed for allocation

The following sites are proposed for allocation and where relevant are inset from the Green Belt:

  • [site details to be added once identified]
  • [site details to be added once identified]
  • [site details to be added once identified]

Supporting text

South Gloucestershire has a well-established gypsy and traveller and travelling showpeople communities. The majority of gypsies and travellers in our area identify themselves as Romany Gypsy and Irish or Scottish Travellers or Travelling Showpeople. These communities reside on a mix of privately owned and social rent sites within our area.

There has historically been a persistent level of unmet need for accommodation for gypsies, travellers and travelling showpeople in South Gloucestershire.

Application of the policy

National Planning Policy for Traveller Sites (PPTS) requires local planning authorities to make an assessment of the needs of gypsies and travellers. The identified need for pitches in South Gloucestershire is therefore 132 new pitches for Gypsies/ Travellers in the period 2022-2042.

One of the aims of PPTS is to promote more private traveller site provision while recognising that there will always be those travellers who cannot provide their own sites. This means that in South Gloucestershire the need is split as follows:

  • 81 private pitches
  • 43 socially provided pitches

In order to meet the need, this plan allocates land at locations detailed above, as defined on the Policies Map. It also includes a permissive and inclusive criteria based policy to facilitate meeting needs, including through applications for windfall sites.

Safeguarded sites

Existing, authorised sites will be safeguarded, and this will apply to public and private gypsy and traveller provision. ‘Authorised’ land includes existing gypsy and traveller sites which benefit from a permanent planning permission or alternatively, a temporary planning permission.

The term ‘safeguarded’ means that existing, authorised land for the accommodation of gypsies and travellers will be retained until such time as it can be proved no longer a need. In order to ensure that those sites that benefit from planning permission (including those with personal or temporary use conditions) are safeguarded and available for gypsy and traveller use going forward, they have been allocated for that specific use. It is important to note that the allocation of sites for gypsy traveller use is for the use of the land only. The number of pitches permitted on a site would remain as allowed by the existing planning permission. Any proposal for the intensification of use of these sites would need to be considered through a new planning application. No further intensification/ development on the site could take place unless expressly permitted.

Safeguarded sites include those within the Green Belt. National planning policy sets out that Green Belt boundaries should only be altered in exceptional circumstances. In the case of gypsy and traveller sites, the demonstrable level of need for sites is considered to provide the justification for this approach.

If, through review of this Plan, it can be demonstrated that there is no longer a need for sites for gypsy and traveller use, this position will be reconsidered.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Sites for Travelling Showpeople

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Policy CS22 – Travelling Showpeople

Purpose

South Gloucestershire is home to a significant population of travelling showpeople whom have been a long-established part of the community. They provide an important service to the community in the form of fairground attractions and mobile catering.

There has been a longstanding shortage of sites for this group in South Gloucestershire. This policy is intended to meet this need, safeguard existing authorised sites, and set out the updated criteria which will be used to determine all planning applications for travelling showpeople.

Policy wording

Sites for travelling showpeople

Proposals for travelling showpeople sites will be considered against the following essential criteria:

  1. Sites should have adequate provision for HGV vehicular access, parking, and manoeuvring;
  2. Sites should not have a significant impact on character and appearance which is unable to be mitigated by landscaping measures;
  3. Sites should be an acceptable level of amenity for site residents and any adjacent residential uses;
  4. Sites should not be located on land that is deemed unsuitable for general housing, such as land that is contaminated (and not capable of remediation), adjacent to refuse sites, landfill sites, heavy industry, or electricity pylons.
    In addition, the following desirable criteria should be considered:
  5. Any opportunities for green infrastructure within the site design;
  6. Any opportunities for adequate play space for children.

Sites for travelling showpeople are as matter of principle acceptable in the open countryside subject to the criteria above. Due to the nature of South Gloucestershire no location should be excluded on the basis of distance to services.

Green Belt

Sites in the Green Belt will only be permitted on the basis of very special circumstances in line with national Planning Policy for Traveller Sites.

The following matters are relevant in establishing the existence of very special circumstances and may be capable of clearly outweighing the harm to the Green Belt:

  • The highly constrained nature of South Gloucestershire;
  • The longstanding unmet need for sites.

Safeguarded sites

Existing authorised land for accommodation by travelling showpeople will be safeguarded at the following sites:

  • Fairlands, Earthcott Green, Alveston*
  • Acres Fair, North Road, Yate
  • Frog Lane, Coalpit Heath*
  • Land at Beanwood Park, Wapley*
  • The Burgage, Chipping Sodbury
  • Land at Cotswold Road, Chipping Sodbury
  • Land at Alexandra Road, Coalpit Heath
  • Land at the Causeway, Coalpit Heath
  • Land at Park Lane, Frampton Cotterell
  • Land adjacent to Hares Farm, Mapleridge Lane, Yate
  • Bristol Rd, Cromhall
  • Engine Common Lane, Yate
  • Land West Of Pound Mill Business Centre, Lower Morton
  • Land at North Road, Yate

Existing sites within the Green Belt (shown with *) are shown on the proposals map and are removed from the Green Belt.

New sites proposed for allocation

The following sites are proposed for allocation and where relevant are inset from the Green Belt:

  • [site details to be added once identified]
  • [site details to be added once identified]
  • [site details to be added once identified]

Supporting text

South Gloucestershire is home to a significant population of travelling showpeople whom have been a long-established part of the community. They provide an important service to the community in the form of fairground attractions and mobile catering.

There has been a longstanding shortage of sites for this group in South Gloucestershire. This policy is intended to meet this need, safeguard existing authorised sites, and set out the updated criteria which will be used to determine all planning applications for travelling showpeople.

Application of the policy

National Planning Policy for Traveller Sites (PPTS) requires local planning authorities to make an assessment of the needs of travelling showpeople. The identified need for pitches in South Gloucestershire is therefore 65 new pitches for travelling showpeople in the period 2022-2042. This includes those who on grounds only of their own or their family’s or dependants’ educational or health needs or old age have ceased to travel temporarily or permanently.

In order to meet the need, this plan allocates land at locations detailed above, as defined on the Policies Map. It also includes a permissive and inclusive criteria-based policy to facilitate meeting needs, including through applications for windfall sites.

Safeguarded sites

Existing, authorised sites will be safeguarded. ‘Authorised’ land includes existing travelling showpeople sites which benefit from a permanent planning permission or alternatively, a temporary or personal planning permission.

The term ‘safeguarded’ means that existing, authorised land for the accommodation of travelling showpeople will be retained until such time as it can be proved no longer a need. In order to ensure that those sites that benefit from planning permission (including those with personal or temporary use conditions) are safeguarded and available for travelling showpeople use going forward, they have been allocated for that specific use. It is important to note that the allocation of sites for travelling showpeople use is for the use of the land only. The number of pitches permitted on a site would remain as allowed by the existing planning permission. Any proposal for the intensification of use of these sites would need to be considered through a new planning application. No further intensification/ development on the site could take place unless expressly permitted.

Safeguarded sites include those within the Green Belt. National planning policy sets out that Green Belt boundaries should only be altered in exceptional circumstances. In the case of sites for travelling showpeople, the demonstrable level of need for sites is considered to provide the justification for this approach.

If, through review of this Plan, it can be demonstrated that there is no longer a need for sites for travelling showpeople use, this position will be reconsidered.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Internal Space and Accessibility Standards

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Policies Sites and Places policy PSP37 – Internal Space and Accessibility Standards for Affordable Dwellings

Purpose

This amended policy on internal space and accessibility standards sets out the requirements that all new types of housing must meet. The policy seeks to apply the Nationally Described Space Standards (NDSS) to market and affordable tenures, thereby ensuring an acceptable level of internal space across all new dwellings. The NDSS is a well-used national space standard and helps to ensure that appropriate living spaces are created.

The policy also sets out requirements relating to accessibility, linked to the Building Regulations 2010 – Access to and use of buildings within Approved Document M, M4(2) and M4(3), whereby specific percentages of dwellings are required to meet these standards.

Homes must provide sufficient space and be adaptable to cater for a variety of different household needs, with the aim of delivering high standards of liveability, accessibility, and comfort. The quality of housing has significant implications for the health and wellbeing of people. Pressures to provide housing and to intensify uses in the urban areas could potentially lead to an erosion of space standards with long-term consequences for health and wellbeing. In order to underpin good practice in the sector, the policy therefore adopts the NDSS, applied to all housing types, including market housing. The NDSS sets out space standards for bedroom sizes, floor to ceiling heights and storage areas, and will ensure that appropriate living spaces are achieved. Applying the NDSS will also ensure that new smaller properties (such as 1 and 2-bedroom flats) which often fall below the standards, are improved.

Where new dwellings are created with sufficient internal space, inhabitants are afforded a range of benefits including; the ability to better socialise with family members and guests, sufficient storage for household items, greater flexibility in arranging rooms to suit need, the ability to work from home, space for effectively managing waste and recycling, adequate access to daylight and ventilation, and allowance for adaptation should inhabitants suffer from permanent or temporary impaired mobility.

Whilst South Gloucestershire is a relatively affluent area, there are pockets of deprivation, with the most deprived areas generally being clustered in urban areas. It is important therefore that space standards are adopted to avoid the creation of substandard dwellings, particularly for those residents who may have the least choices who are in smaller dwellings as that is the only option that is possible for them.

Accessible homes support the changing needs of residents from raising children through to mobility issues faced due to frailty, old age or through disability. The standards allow people to live independently maintaining their health and wellbeing for as much of their life as possible, either in their existing home or in alternative accommodation to meet their changing needs and aspiration within their neighbourhood or local area. This helps to promote safe, accessible environments that promote inclusion and community cohesion.

Policy wording

  1. All new housing (Market and Affordable) will be required to meet M4(2) accessible and adaptable dwellings standard, and the Nationally Described Space Standards (NDSS) or future equivalent/successor. An accompanying table should be provided for each application, setting out for each dwelling; areas for bedrooms, storage, floorspace and ceiling heights.
  2. Affordable Housing should:
    • i. provide 10% of dwellings built to meet the M4(3) (2a) standard (wheelchair adaptable housing); and
  3. Market housing should:
    • i. provide 4% of dwellings built to meet the M4(3) (2a) standard (wheelchair adaptable housing); and
  4. For age restricted housing for older people, all dwellings, irrespective of tenure will be required to meet Building Regulation M4(3) (2a) standard (wheelchair adaptable housing).
  5. In exceptional circumstances, where there are factors such as vulnerability to flooding, site topography and where the provision of a lift to dwelling entrances may not be achievable, the council may agree a reduced requirement in terms of Building Regulation M4(2) and M4(3) accessibility standards.

Supporting text

Space Standards

In March 2015 the Government introduced optional Nationally Described Space Standards through the Housing Standards Review. In addition, the council’s Sustainable Community Strategy promotes suitable housing and healthy lifestyles, while the Local Plan also promotes high-quality design and health and well-being objectives.

Homes must provide sufficient space and be adaptable to cater for a variety of different household needs, with the aim of delivering high standards of liveability, accessibility, and comfort. The quality of housing has significant implications for the health and wellbeing of people. Pressures to provide housing and to intensify uses in the urban areas could potentially lead to an erosion of space standards with long-term consequences for health and wellbeing. In order to underpin good practice in the sector, the policy therefore adopts the Nationally Described Space Standards, applied to all housing types, including market housing.

In accordance with the PPG requirements, Local Authorities should conclude whether there is a local need to implement space standards, and if so, the Local Authorities should collect evidence on the size and types of dwellings being built in the area. To do so, a data analysis exercise to assess space standards within built developments has been carried out and will be released in support of this policy at Regulation 19 stage.

There is substantial evidence on the impact of housing and the homes in which we live, on health and well-being1. The Covid-19 pandemic has drawn greater attention to the link between housing, health, and equity and the importance of homes2 and indoor and outdoor space3 and has exposed and amplified housing-related health inequalities4. Research carried out during the pandemic highlighted that 31% of adults in Britain have been affected by mental or physical health problems due to the condition of, or lack of space in, their home during lockdown5.

There are various ways in which the amount of space in a house may impact on health. Whilst the relationship is complex, several studies provide strong evidence of an association. Evidence suggests associations between overcrowded and inadequate space and poor health and development rates,6 infectious diseases, particularly respiratory illness, mental health and stress, and educational attainment7.

Accessibility Standards

The policy requirements relating to accessibility are linked to the Building Regulations 2010 – Access to and use of buildings within Approved Document M, M4(2) and M4(3), whereby specific percentages of dwellings are required to meet these standards. The different categories are set out below.

  • M4(1) Category 1: Visitable dwellings
  • M4(2) Category 2: Accessible and adaptable dwellings
  • M4(3) Category 3: Wheelchair user dwellings
  • Within the M4(3) standard there are two sub-categories:
  • M4(3)(2a): wheelchair adaptable (meaning that they meet spatial and layout requirements but may not have been fully fitted and finished to accommodate immediate use by a wheelchair user)
  • M4(3)(2b): wheelchair accessible (meaning that the dwelling is fully ready for occupation by a wheelchair user household)

The provision of appropriate housing for older and disabled people makes an important contribution to a safe and independent life. An ageing population will see the numbers of disabled people continuing to increase and it is important to plan early to meet the needs through policy change. In South Gloucestershire, 19% of the population are aged over 65, which is expected to increase to 21% by 2043. Raising the accessibility standards of new homes will have a positive impact on household health and welfare, and are particularly relevant to the protected groups, age and disability.

While features of accessible and adaptable homes support people with physical disabilities and for people living with a reduction in their mobility, the accessible and adaptable features also support wider and other disabilities. For example, the presence of toilets on the ground floor will support people with invisible disabilities and other mental health or sensory issues.

The South Gloucestershire Housing Strategy 2023, highlights the impact that housing has on health and wellbeing, recognising that to reduce health inequalities, all aspects of housing must make a positive contribution to the health of both individuals and communities. It outlines within its key themes, the objectives that aim to deliver this through the NDSS, M4(2) and M4(3) standards.

There are circumstances where a range of factors, such as vulnerability to flooding, or site topography, might impact on the ability to achieve Building Regulations M4(2) and M4(3). In these exceptional circumstances, the council may agree a reduced requirement. Any reduction would need to be supported by fully justified reasons.

Application of Policy

The council will generally seek to support truly innovative housing. Where it can be demonstrated that a dwelling will provide high levels of amenity through, for example, innovative methods of storage, high levels of daylight, and direct access to outdoor private space, the council may make an exception and permit affordable dwellings below the prescribed space standards.

Footnotes

  1. Green et al. (2022). Maximising health and well-being opportunities for spatial planning in the COVID-19 pandemic recovery. Cardiff, Public Health Wales NHS Trust.
  2. Town and Country Planning Association. (2021) 20-Minute Neighbourhoods – Creating Healthier, Active, Prosperous Communities An Introduction for Council Planners in England.
  3. Tinson, A. and Clair, A. (2020). Better housing is crucial for our health and the COVID-19 recovery.
  4. Homes-health-and-COV19-poor-quality-homes.pdf (ageing-better.org.uk)
  5. National Housing Federation. (2020). Housing issues during lockdown: health, space and overcrowding.
  6. Office of the Deputy Prime Minister. (2004). The Impact of Overcrowding on Health and Education: A review of the Evidence and Literature
  7. Full article: Housing space and occupancy standards: developing evidence for policy from a health and wellbeing perspective in the UK context (tandfonline.com)

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Minerals

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Core Strategy Policy CS10 – Minerals

Policies, Sites and Places (PSP) Plan Policy PSP23 – Mineral working and extraction

Purpose

Ensuring that there is a sufficient supply of minerals to provide the infrastructure, buildings, energy and goods that the country needs is a key objective of our new Local Plan.

National Planning Policy Guidance on Minerals paragraph 060 states that as part of the Managed Aggregate Supply System, at local level, mineral planning authorities are expected to prepare Local Aggregate Assessments (LAAs)to assess the demand for and supply of aggregates.

Paragraph 213 of the NPPF states that minerals planning authorities should plan for a steady and adequate supply of aggregates by various means, including preparing LAAs, and using landbanks of aggregate minerals reserves principally as an indicator of the security of aggregate minerals supply, and to indicate the additional provision that needs to be made for new aggregate extraction and alternative supplies in mineral plans.

The purpose of this policy is to ensure that there is a steady and adequate supply of minerals and maintain a 10 year land bank throughout and beyond the plan period.

It will do so by allocating areas for mineral working where necessary, having regard to the need to promote deliverability of permitted reserves of crushed rock. It also sets out the environmental considerations that will need to be taken into account for proposals for new extraction, and the council’s expectations for the restoration of quarries once they have ceased extraction operations.

Policy wording

The council will plan for a steady and adequate supply of aggregates by seeking to maintain a land bank for crushed rock of at least ten years, and allocating areas for mineral working where necessary, having regard to the need to promote deliverability of permitted reserves of crushed rock. To this end, provision is made for the extraction of crushed rock through the following preferred areas, as defined on the Policies Map:

  • Cromhall Quarry
  • Tytherington Quarry southwest (phases 1-3)
  • Wickwar Quarry northwest

As part of this approach, the council will also encourage the provision of recycled aggregates.

Ancillary and Secondary Operations

Development proposal(s) related to operations ancillary or secondary to the primary activity on the mineral site will be acceptable where the development proposal(s) primarily uses material extracted from the site. The operation and retention of such development will be limited to the permitted life of the site for mineral extraction.

Environmental Considerations

Development proposals for new mineral workings will need to demonstrate that permitted operations will not have unacceptable adverse impacts on the natural and historic environment, human health, or local amenity. Proposals will also need to comply with the Plan as a whole, however in considering unique issues associated with mineral workings, proposals will also, in line with government guidance, likely need to consider:

  • i) blasting/vibration; and
  • ii) separation and buffer zones

Restoration

Restoration and aftercare of mineral development should be in keeping with the character and setting of the local area and should contribute to the delivery of uses, which include, agriculture, geodiversity, biodiversity and habitats, native woodland, the historic environment or recreation, where these are consistent with the Local Plan.

Where possible and practicable, progressive restoration and aftercare will be required. Where this is not possible, restoration and aftercare should be carried out following completion of mineral working at the earliest possible opportunity, to a timescale to be agreed with the council and completed without delay.

Supporting text

National policy requires that provision is made for a steady and adequate supply of minerals to support the economy, that the best use is made of these resources and that they are protected for the longer term. Provision of supplies to meet current needs is achieved through the maintenance of ‘landbanks’ (mineral reserves with planning permission for extraction), while future supplies are protected through Mineral Safeguarding Areas (areas with mineral resources which do not yet have planning permission for extraction).

South Gloucestershire primarily contributes to minerals supply by the winning and working of carboniferous limestone, producing aggregate (crushed rock). The aggregate is mainly used for building and repairing roads and producing asphalt, concrete and concrete products. To a lesser extent, South Gloucestershire also produces brick making clay, and historically other minerals have also been worked in the area.

Existing supply and establishing need

Based on a long-standing agreement, the required crushed rock provision for the WoE is split 60%/40% between South Gloucestershire and North Somerset.

On this basis, given the ten-year average in the emerging WoE LAA for 2012-2021 of 3.72mtpa, the annualised required level of crushed rock provision for South Gloucestershire can be calculated as 60% of 3.72mtpa, which is 2.32mtpa. If this was to be extrapolated, the total crushed rock requirement for South Gloucestershire for 2022-2040 inclusive (18 years) would be 40.18mt. To allow for a ten-year landbank at the end of that period, a further 10 years requirement can be added on (23.2mt), so, on that basis, the total South Gloucestershire crushed rock requirement for that 28 year period (to 2050) would be 63.38mt. This figure is based on the ten-year sales average in the latest published LAA (covering the period 2012-2021). Future LAAs are likely to give different ten-year averages, and hence different figures. Therefore it is simpler and more meaningful to aim to maintain a ten-year landbank (with the landbank to be measured annually and based on 60% of the ten-year average sales figure in the latest LAA), in line with national planning practice guidance.

Meeting the demand

The preferred areas allocated through the Local Plan contribute to achieving a 10 year landbank for crushed rock.

Cromhall Quarry includes an identified resource of circa 18mt. As it stands, the intention is that output will be on a relatively small scale, initially with a saleable output of circa 0.25mt per annum, although we understand there is potential for this to be scaled up mid-way through the Plan period if required.

The three-phased extension to Tytherington Quarry includes the potential for extraction over approx 60 hectares of land, with an identified resource of circa 76mt, which will help to ensure a landbank through this Plan period and into the next.

The extension to Wickwar Quarry includes an identified resource of circa 35-40mt. As it stands, the intention is that, following allocation through the Local Plan, planning permission will be secured by 2033. This would facilitate the continuity of a supply of up to 1.2mt per annum into the nearby markets.

If, through annual monitoring, it appears that the ten-year landbank might not be maintained, it may be necessary to revisit the issue of permitting further reserves.

Outside Preferred Areas

Extraction of crushed rock outside of the preferred areas and area of search will not be permitted, except at the boundaries of existing quarries, where this would prevent mineral sterilisation. Considerations should include protection of designated sites and the amenity of local communities.

Environmental considerations

National policy requires that operations for mineral workings, where practical, occur outside of nationally designated sites, such as Areas of Outstanding Natural Beauty. The scope of issues to be included is likely to be wide and varied, and other policies in this plan will also be appropriate to apply to proposals. In addition, some specialist issues associated with mineral workings will also need to be taken into account, such as blasting/vibration and separation and buffer zones and impacts on water resources8. The issues to be considered in relation to a particular site proposal should be agreed with the council.

Restoration and aftercare

Restoration and aftercare proposals for a mineral working site will be conditioned as part of planning permission. Schemes for restoration and aftercare should be in place prior to any approval of permission for mineral workings and should be reviewed prior to works commencing, to take account of changing local circumstances and environmental needs. The council requires that all quarry sites are subject to restoration. Where additional landfilling and/or the importation of waste is required, this would normally require separate permission, the timescales of which would be addressed as part of the determination of such an application.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Economy and Jobs

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Core Strategy Policy CS11 – Distribution of Economic Development Land

Core Strategy Policy CS12 – Safeguarded Areas for Economic Development

Core Strategy Policy CS13 – Non-Safeguarded Economic Development Sites

Purpose

Housing a growing population needs to be balanced with providing sufficient jobs for existing and new residents, and ensuring there is enough land to accommodate these jobs. Having land of the right type and in the right places also supports a strong, responsive and competitive economy, ensure people have access to employment opportunities close to where they live, to manage the impacts of climate change and assist in meeting a zero-carbon ambition.

South Gloucestershire has experienced high job growth rates and low unemployment. It includes three Enterprise Areas (Filton, Emersons Green and Severnside), each with their own economic specialisms and sector focus. We have strong performing locations contributing to the West of England, and the National, economy. Maintaining strong economic performance will only be achieved by having designated areas where land is safeguarded for employment uses.

Providing and safeguarding land for employment also reflects Local Plan objectives of making the most effective use of land within our urban areas and market towns and identifying areas of transformational change. Where we are not able to meet our needs for new jobs within those, part of our strategy for homes and jobs is exploring opportunities for new employment areas, alongside new housing, to meet that need.

Providing more, and a wider range, of jobs locally can enable people to work closer to home, helping to grow the local economy and make journeys to work shorter and more by walking, wheeling or public transport. This in turn would help address both the cost of living and the impacts of climate change.

The following three functional economic areas are clearly identifiable within South Gloucestershire:

  • North Fringe of Bristol Urban Area – A dense employment and residential location on the outskirts of Bristol, which includes the Filton Enterprise area, Ministry of Defence and University of the West of England. It is a strategic employment location for the West of England, including being an established hub for aerospace and advanced engineering, and with a strong focus on manufacturing, wholesale and retail trade, public administration, professional, scientific and technical sectors.
  • East Fringe of Bristol Urban Area – Also on the outskirts of Bristol the East Fringe provides the highest residential concentration for South Gloucestershire, with key strategic employment assets such as the Bristol and Bath Science Park and the National Composite Centre, both within the Emersons Green Enterprise Area. There is separation however between these assets and the wider East Fringe, extending south to Hanham, which does not have a clear employment specialism, with significantly fewer employment areas, some of which have recently been lost to other uses. Many of the remaining areas need investment to modernise and adapt to modern business needs, but currently still provide low-cost premises for smaller businesses and as such are a valuable resource.
  • Severnside – A strategic location adjacent to the M5 and M49 motorways, near to the Port at Avonmouth, with low residential population as result of factors such as flood risk and poor public transport connections. It is however a significant economic centre for South Gloucestershire, with strong road transport links from the motorway network. Severnside forms part of the regionally significant Avonmouth Severnside Enterprise Area, with focus of large-scale distribution and manufacturing.

Outside of these, the following functional economic areas can broadly be identified:

  • Yate and Surrounding Areas – A notable employment area, reflecting location-specific demand, extending from the M4 north to Wickwar. Most jobs are concentrated in the West Yate employment area, where Beeches Industrial Estate and Greater Western Business Park are located as well as other industrial estates (Westerleigh Business Park, Badminton Road Trading Estate) with predominantly large industrial, storage and distribution uses. There are opportunities to intensify and diversify the employment offer in these areas, to maximise their capacity. This could include redevelopment to smaller and light industrial and manufacturing uses, and local services that are more flexible and adaptable to changing economic needs. Wholesale and retail also account for a significant part of the area’s employment with Yate Town Centre representing an important retail location.
  • Thornbury and North Rural – A more rural area, including Almondsbury to the South, Oldbury Power Station to the west, Falfield and Charfield to the north, the local economy does not show any sign of industrial specialisation.
  • South and East Rural – Covers the eastern edge of South Gloucestershire from Hawkesbury Upton in the north to Marshfield and Bitton in the south. The southern part of the area is relatively well connected to the rest of South Gloucestershire and the Bristol urban area, by the M4 and A420 into the East Fringe, and to Bath via the A46. However, developments are restricted due to Green Belt designation that covers most of that part of the area, as well as the Cotswold AONB. The northern part of the area is outside of the Green Belt, but still within the AONB and significantly further from the main employment and amenities area and therefore less attractive to employment sectors. Similar to Thornbury and North Rural area, the economy does not show clear specialisation.

It is therefore important that the Local Plan safeguards a portfolio of areas for employment uses across the district. This needs to take account of losses over the previous local plan period by making the best use of existing safeguarded areas, allocating new safeguarded areas, and managing change on them to ensure development proposals do not harm their employment offer. Priority on safeguarded employment areas is for uses falling within Classes E(g), B2, and B8 of the Use Classes Order 1987 (as amended), or any future equivalent provision.

Within these priority uses, intensifying and diversifying safeguarded areas would assist both making efficient use of land, and safeguarded areas becoming more flexible and adaptable to changing economic circumstances.

Until replaced, saved Policies, Sites and Places Plan policy PSP27 provides criteria for proposals falling within Use Class B8, with Severnside considered the main focus for large-scale strategic distribution and logistics. The benefits of ancillary offices to B8 uses may also form an important consideration.

Policy wording

  1. The council will maintain a supply of land for Economic Development, distributed in accordance with Table 1. In addition, there is also provision for employment uses within non-safeguarded areas.
  2. Land identified in Table 2 shall be retained as Safeguarded Areas for Economic Development, and reserved for Priority Employment Uses. Proposals for change to other economic development uses will be permitted where it can be clearly demonstrated, through adequate marketing and other relevant evidence, that individually and/or cumulatively with other completed and permitted developments:
    • a. the proposal would not prejudice the regeneration and retention of priority employment uses elsewhere within the defined employment area; and
    • b. that it would contribute to a more sustainable pattern of development in the local area due to appropriateness of the proposed economic development use to the location; and
    • c. the proposal would improve the site’s economic output through the number or range of jobs available in the local area, or through another appropriate economic indicator; and
    • d. no suitable alternative provision for the proposal has been made elsewhere in the Local Plan.

      Proposals for non-economic development uses will not be permitted, except for operational development required to support existing economic development uses that complies with criterion 2a) and is small in scale relative to the Safeguarded Area for Economic Development in which it is proposed.

      All proposals within Safeguarded Areas for Economic Development, including for priority employment uses, should make efficient use of land.
  3. Proposals for change of use within non-safeguarded economic development sites, to non-economic uses, will be refused unless they comply with the following sequential approach:
    • i. Economic development re-use of the whole site
    • ii. An economic development led mixed-use scheme
    • iii. A non-economic development led mixed-use scheme
    • iv. A non-economic development only scheme.

      It must be clearly demonstrated, through adequate marketing and other relevant evidence, that all reasonable attempts have been made to secure a use higher in the sequence before moving to the next. Financial contributions secured through an appropriate mechanism will be required to enable assessment by the council.

      For proposals within the Communities of the East Fringe of Bristol Urban Area, the provisions of criterion 4 shall additionally apply.

      The above requirements will also apply to proposals within Safeguarded Areas for Economic Development, in situations where the benefits of the proposal are considered to outweigh the conflict with criterion 2.
  4. Proposals on both safeguarded and non-safeguarded areas for economic development within the Communities of the East Fringe of Bristol Urban Area, which improve employment opportunities for the East Fringe communities, will be supported. Proposals resulting in complete or substantial loss of economic development land and/or buildings to non-economic development uses will not be permitted. New employment opportunities being created will need to be evidenced as appropriate to their location, having a reasonable prospect of coming forward, and having a marketing strategy for the proposed and alternative economic uses.
  5. Within strategic allocations, new areas and sites proposed for economic development uses should aim to maximise employment density and be appropriate to their location, including being compatible with their surroundings, and having sufficient parking and suitable access for cars and goods vehicles both through the wider development and to the Strategic Road Network.
  6. Proposals comprising 10 or more residential dwellings, 1,000 square metres of new non-residential floorspace, or loss of 1,000 square metres economic development floorspace, will be expected to facilitate access for local residents to employment and training. This should include, but not be limited to, supporting employment initiatives, skills development, and sustainable travel measures within the completed development itself and through the construction/ supply chain. The benefit which may be attributed to these should be demonstrated through suitable evidence.

Supporting text

Table 1 – Distribution of Economic Development Land

North Fringe of Bristol Urban Area

Safeguarded Land TBC ha 
Allocated within the Former Filton Airfield TBC sqm 
Allocated within Filton 20 Business Park (Potential LP Option) TBC sqm 
Allocated within University of the West of England (Potential LP Option) TBC sqm 

East Fringe of Bristol Urban Area

Safeguarded Land TBC Ha 
Allocated at Emersons Green TBC sqm 
Allocated within Former Lucas Works TBC sqm 
Allocated within Former Kleeneze Site TBC sqm 

Severnside

Safeguarded Land TBC Ha 

Yate and Surrounding Areas

Safeguarded Land TBC Ha 
Allocated within North Yate New Neighbourhood TBC ha 

Thornbury and North Rural

Safeguarded Land TBC Ha 
Allocated Sites TBC Ha 

South and East Rural

Safeguarded Land TBC Ha 
Allocated Sites TBC Ha 

This distribution of Economic Development land is provided through the safeguarded areas listed within Table 2.

Table 2 – Safeguarded Areas for Economic Development

North Fringe of Bristol Urban Area

SG-1 Abbey Wood Business Park SG-2a Almondsbury Business Park (Western Site) 
SG-2b Almondsbury Business Park (Central Site) SG-2c Almondsbury Business Park (Eastern Site) 
SG-3 Aztec West Business Park SG-4 Bristol Business Park 
SG-5 Employment Land at Filton Northfield SG-6a – Land East of A38, Filton/Patchway (North Parcel) 
SG-6b – Land East of A38, Filton/Patchway (Rolls Royce Main) SG-6c – Land East of A38, Filton/Patchway (South of B4057) 
SG-6d – Land East of A38, Filton/Patchway (South Parcel) SG-7a Land West of A38 and South of Hallen Railway Line (Airbus Filton Campus, Aerospace Business Park, and Brabazon Business Park) 
SG-7b Land West of A38 and South of Hallen Railway Line (Filton 20 Business Park) SG-8 Ministry of Defence, Abbey Wood 
SG-9 Old Gloucester Road, Hambrook SG-10 Parkway Business Park 
SG-11 Parkway North Business Park SG-47a Cribbs Causeway, Lysander Road North 
SG-47b Cribbs Causeway, The Laurels SG-47c Cribbs Causeway, Lysander Road South 
SG-48 Jupiter Road SG-49 Patchway industrial Estate 
SG-50 Pearce/Auto Techniques Site SG-51a University of the West of England (North) 
SG-51b University of the West of England (South) SG-52 Land West of A38 (inc. runway and Royal Mail site) – Former Filton Airfield Allocation 

East Fringe of Bristol Urban Area

SG-12a Emersons Green (Bristol and Bath Science Park) SG-12b Emersons Green (Emerald Park and Harlequin Office Park) 
SG-12c Emersons Green (Vertex Park and Residual) (Remainder) SG-13 Chapel Lane, Warmley 
SG-14a Tower Road, Warmley (Eastern Site) SG-14b Tower Road, Warmley (Western Site) 
SG-15 Bristol Uniforms Site (Pending outcome of LP Option) SG-16 Oatley Trading Estate, Kingswood 
SG-17 The Civic Centre, Kingswood SG-18 Station Road, Kingswood 
SG-19a North of Douglas Road (Wood Road/Moravian Road) SG-19b North of Douglas Road (Lucas Works) (Pending outcome of LP Option) 
SG-20 Eclipse Office Park SG-21 McBraida Site 
SG-22 Longwell Green Industrial Estate SG-23a Southway Drive, North Common (North Site) 
SG-23b Southway Drive, North Common (South Site) SG-24 Hanham Business Park 
SG-25 Former Kleeneze Site (Remainder) SG-26 Bath Road, Bitton 
SG-27 Hayward Industrial Estate SG-28 2-8 London Road, Warmley 

Yate and Surrounding Areas

SG-29 Beeches Industrial Estate, Yate SG-30 Bowling Hill, Chipping Sodbury 
SG-31 Broad Lane, Yate SG-32 Council Offices, Badminton Road, Yate 
SG-33 Great Western Business Park, Yate SG-34 Indesit Site, Station Road, Yate 
SG-35 The Ridge, Yate SG-36 Westerleigh Business Park, Yate 
SG-39 Arnold Fields Trading Estate,  Wickwar SG-40 Old Cider Mill Trading Estate, Wickwar 
SG-42 Station Premises and Yard, Winterbourne SG-53 Badminton Court/Dairy Crest Site, Yate 
SG-55 Hatters Lane, Chipping Sodbury SG-57 Stover Road + North Road Industrial Estate, Yate 
SG-58 Badminton Road Trading Estate, Yate North Yate New Neighbourhood – New

South and East Rural

SG-41 Pucklechurch Trading Estate SG-44 Sunguard Vivista Premises, Marshfield 

Severnside

SG-45a Severnside Employment Area (Westgate) SG-45b Severnside Employment Area,  Central Park South 
SG-45c Severnside Employment Area,  Central Park SG-45d Severnside Employment Area,  Old Power Station Site 
SG-45e Severnside Employment Area,  Mount Park and Surroundings  

Thornbury and North Rural

SG-37 Thornbury Industrial Estate SG-43 Station Road, Charfield 

Definition of Priority Employment Uses

Priority Uses are those falling within:

Use Class E(g)(i) – Office
Use Class E(g)(ii) – Research and Development
Use Class E(g)(iii) – Light Industrial
Use Class B2 – General Industry
Use Class B8 – Storage and Distribution

of the Use Classes Order 1987 (as amended), or any future equivalent provision.

Definition of Economic Development

Economic development includes development within Use Classes E(g), B2 and B8, public and community uses, and main town centre uses. It also includes other development which achieves at least one of the following objectives:

  1. provides employment opportunities;
  2. generates wealth; or
  3. produces or generates an economic output or product.

Main town centre uses are as defined within the National Planning Policy Framework (Currently Annexe 2: Glossary) and will need to meet requirements of the sequential test as set out nationally and in Policy: Town Centres.

Office development outside town centres may be appropriate as this reflects the existing pattern of development in South Gloucestershire and is in line with the local and sub-regional strategy.

The definition of economic development does not include residential developments falling within Use Classes C2 and C3. These will be assessed as non-economic development uses for proposals on safeguarded or non-safeguarded employment sites.

While the definition is broad, not all uses are appropriate in all locations. In particular, the strategy and policies distinguish between uses of a traditional employment character and those which are appropriate in a town centre location.

Safeguarded Areas for Economic Development

The South Gloucestershire Employment Land Review (2022) identified the majority of existing safeguarded employment areas should be retained to meet the future economic needs of South Gloucestershire. As part of producing a new Local Plan, some areas are being reviewed as urban option sites, and new employment areas are proposed to be safeguarded, to meet future assessed needs and employment growth, address imbalance in some locations (the East Fringe in particular) between jobs and resident workers, and to support our rural economy.

Priority Employment Uses are anticipated to be the focus for sites listed in table 2, however flexibility for changing economic conditions is allowed for provided that the requirements of criterions 2 and 3 are met.

Some operational development uses, both economic or non-economic, may be appropriate where they support existing economic development uses, for example those that clearly assist with their operation or provide an amenity service or function to workers, and as such support economic success of the safeguarded area. Any such uses must still comply with criterion 2a) and small-scale relative to the safeguarded area.

Within the boundaries of some safeguarded areas there are areas of Green Infrastructure which will continue to be protected and managed as green assets.

Assessing contributions to sustainable patterns of development includes consideration of the range of jobs and services in the locality, transport and accessibility, the availability of alternative locations and the relationship to town and local centres.

Opportunities to redevelop existing employment sites, through intensification or re-modelling, will be encouraged. Redevelopment can increase productivity through the more efficient use of land and enable the site to make a better contribution to the local area through better design and improving the number and range of jobs available. Where major change is proposed, more detailed guidance should be prepared.

Non-Safeguarded Sites

Evidence shows that locally significant amounts of non-safeguarded employment land have been lost to residential uses in the urban areas and villages. The need to prevent further losses of smaller scale employment opportunities in the context of pressure to meet housing targets has been identified through engagement as a key issue. In the light of local evidence of loss of employment sites in villages, this policy sets out a preferred sequence for change of use on economic development sites and a process for determining when change of use would be acceptable.

Proposals for residential re-use of buildings will need to be accompanied by a statement clearly demonstrating that a market appraisal has been undertaken to assess alternative economic development uses, and that every reasonable attempt to secure a suitable economic re-use, and after this a mixed use, has been made and failed. This assessment should demonstrate that a sustainable solution for the local community has been found. In some cases, a mixed use or residential scheme may be the most sustainable and appropriate solution for a site.

Definition of Adequate Marketing

The council is preparing guidance which applicants should refer to covering the factors which will be considered for assessment of the adequacy of marketing undertaken. It will need to be evidenced that there is no demand for existing commercial premises and sites, and that they have been actively marketed without success. In respect of Criterion 3, this needs to be demonstrated for each use higher in sequence before moving to the next.

Assessment of commercial marketing has significant resource implications for the council, potentially requiring consultant support. It is therefore relevant and necessary to secure a financial contribution from applicants for proposals where the requirements under criterion 3 arise. A Planning Performance Agreement or other appropriate mechanism may be used to secure this. Whilst proposals for changes to other economic development uses under criterion 2 have some resource implications, these are unlikely to be as extensive, and positive changes within safeguarded sites would not wish to be discouraged.

Strategic Allocations

Criterion 5 seeks to ensure that economic development uses within allocated sites are appropriately located within the wider development, particularly those which are mixed use with residential. This should be considered as part of the sitewide masterplan or other stage of approval. Car and goods vehicle parking provision should also comply with Policy: Parking Requirements, including electric vehicles.

Enabling Access to Employment and Skills Development

The intention of criterion 6 is to enable local residents to benefit from new development, or to help mitigate the effects of employment losses, by enhancing their employment and training prospects, particularly for residents of priority neighbourhoods and other disadvantaged groups including people with learning disability, and assist with sustainable travel measures for these residents to reach employment locations. Such benefit may arise during both construction and operation of the development, include apprenticeships and other pathways to access employment and to increase the skills of the local workforce, promoting employment within the locality such as nearby schools, colleges, and job shops, commitments to recruiting a proportion of new employees from the local area, and commitments to placing work with local suppliers.

The council will work with its partners to prepare a planning obligations SPD supporting the approach to realising the economic benefits of new development for local residents.

Question

Do you agree with our proposed policy approach?

Send us your feedback by completing the questionnaire on our consultation page.

Town Centres

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Core Strategy policy CS14 – Town Centres and Retail

Policies Sites and Places Plan policy PSP31 – Town Centre Uses

Purpose

Town Centres support the Urban Lifestyles approach by offering opportunities to access a range of facilities and services by walking, cycling, and wheeling. They also provide public transport connections to a wide range of locations. This policy is aimed at promoting the vitality and viability of centres, recognising their importance to the local community and economy, their social function, and their sense of place.

National policy requires a network and hierarchy of town centres to be defined. Most services and town centres in South Gloucestershire are located within the North and East Fringes of Bristol urban areas, together with our three market towns. These centres, particularly the traditional ones, are highly valued by their local communities for their heritage and functions. In addition to retail all the centres provide, to a greater or lesser extent, a range of services and facilities including financial, community, leisure, employment and housing.

Primary Shopping Areas have a focus on shops for food, drink, clothing and household goods. Controls over this are impacted by the range of permitted development rights for main town centre uses, but where planning permission is required, priority will be given to retail uses. Other main town centre uses, such as restaurants, cinemas and offices, will be directed to the wider town centre boundaries.

National policy also requires sites to be allocated to meet the needs of retail, leisure, office and other main town centre uses looking at least 10 years ahead. However, permitted development rights for town centre uses have extended over recent years and our town centres and high streets are also ever-changing, making estimating more difficult.

The effects of Covid-19 have further changed the role of town centres, which need to diversify with a wider range of services and be hubs for local communities. As part of the Urban Lifestyles approach, co-locating living and working within town centres will also assist them to stay viable and give them new purpose.

49 local centres are also within the urban area and larger village settlements which meet the needs of residents for everyday convenience goods and basic services within walking distance, thereby providing an essential and valuable service. Additionally, 3 new local centres are currently identified. Until replaced, saved Policies Sites and Places Plan policy PSP32: Local Centres, Parades and facilities, provides criteria for proposals relating to these. There are also smaller village services and local shops throughout the district.

Policy wording

Hierarchy of Centres

1. Development proposals for main town centre uses, as defined by National policy, shall be directed sequentially to South Gloucestershire’s Town Centres identified in the Policies Map, and Table 1.

Proposals for main town centre uses within local centres, also listed in Table 1, will be acceptable where they are of a scale and size appropriate to the location.

Cribbs Causeway/Mall, Abbey Wood and Longwell Green Retail Parks will be treated as out-of-centre and development proposals within these will need to satisfy the sequential test, and the impact test where required under criterion 10.

Creation of new Town and Local centres

2. New centres may be established over the plan period, or existing retail and leisure uses adapted, to support new settlement, urban extensions and new communities. Any new centres or adapted uses should be of an appropriate scale for the locality and not undermine the vitality, viability, role or function of existing centres within the hierarchy.

3. New centres proposed, or adapted uses, should provide the number and range of facilities to meet needs of the communities they are intended to serve.

Primary Shopping Areas

4. Primary shopping areas, as defined on the Policies Map, will be the focus for comparison and convenience retailing, including both large and smaller scale retail proposals. Within these, changes of use to ground floor residential development (that require planning permission) will not be permitted.

5. Outside of designated Primary Shopping Areas, but within wider town centre boundaries, small scale retail proposal(s) to meet local community needs will be acceptable. Proposals for change of use to ground floor to residential development (that require planning permission) will need to demonstrate that:

  • Following effective marketing that there is no realistic prospect of securing the continued existing use of the unit, nor any alternative main town centre use within it; and
  • The proposal would not, individually or cumulatively, have a detrimental impact upon adjoining commercial uses nor the vitality and viability of the wider town centre.

6. Both within designated Primary Shopping Areas and wider town centre boundaries, new residential development which makes positive use of underused and/or vacant upper floors will be encouraged provided they would not, individually and/or cumulatively, have a detrimental impact upon adjoining commercial uses nor the vitality and viability of the wider town centre.

Edge of Centre Development Proposals

7. Edge of centre proposals for main town centre uses will only be acceptable where it has been demonstrated that:

  • there are no suitable more central sites to accommodate the proposal;
  • flexibility of the proposal has been demonstrated including consideration of alternative formats and scales;
  • the proposal would support the role of the centre, and be of a scale proportionate to the centre; and
  • the site would be accessible and well connected by pedestrian, cycle, and public transport links to the town centre.

Out of Centre Development Proposals

8. Out of centre proposals for main town centre uses will only be acceptable where it has been demonstrated that:

  • no suitable centre or edge of centre sites are available (or expected to become available within a reasonable period) to accommodate the proposal;
  • Flexibility of the proposal has been demonstrated including consideration of alternative formats and scales; and
  • the site would be accessible and well connected by pedestrian, cycle, and public transport links to an established town centre.

9. When considered cumulatively with; recently completed developments in the plan period, outstanding planning permissions and allocations in the catchment area they serve; out of centre development proposals should not have an unacceptable impact on:

  • a) existing, committed and planned public and private investment in a centre (or centres) lying within the catchment area of the proposal(s); and
  • b) the vitality and viability of established centres.

10. An impact assessment will be required for:

  • a) retail proposal(s) larger than 350m² in all locations outside Primary Shopping Areas; or
  • b) with exception of offices, main town centre use proposal(s) above 1000m², where they are outside of the designated Town Centre boundary; or
  • c) office proposal(s) larger than 10,000m², where they are outside of the designated Town Centre boundary.

Markets and Garden Centres

11. Development proposal(s) which would undermine or lead to the loss of existing markets will be acceptable where appropriate alternative market provision would be provided.

12. Development proposal(s) for new garden centres will need to follow the sequential and impact tests. Development proposal(s) to remodel existing garden centres will be assessed to ensure that any general sales, and other uses taking place within them, remain ancillary to the plant sales.

General Assessment Criteria

13. Development proposals for all main town centre uses, including retail, in any location, should:

  • positively respond to any centre specific health check or locally prepared and endorsed vision;
  • be in proportion to the role and function of the location;
  • ensure any shopfront(s), sign(s) or advertisement(s), are of a scale, detail, siting and type of illumination appropriate to the character of the host building, wider street scene and avoids harmful effects on amenity of the surrounding area; and
  • have convenient, safe and attractive access to and from surrounding residential areas for pedestrians and cyclists; and
  • have appropriate provision for parking and servicing; and
  • not give rise to unacceptable levels of vehicular traffic to the detriment of the amenities of the surrounding area and highway safety; and
  • where possible and viable include and make positive use of upper floors; and
  • demonstrate a positive contribution towards the public realm and non-car circulation; and
  • be well served by public transport.

Supporting text

Table 1 – Hierarchy of Centres

North Fringe of Bristol Urban Area

Town centres

Bradley Stoke Filton 
Patchway Stoke Gifford 

Local centres

Gloucester Road North Gloucester Road, Patchway 
Filton Avenue (Nos. 508-550 and 551-557) Kingsway, Little Stoke 
Filton Avenue (at junction with Conygre Rd) Chelford Grove, Patchway 
Station Road, Filton Ratcliffe Drive, Stoke Gifford 
The Parade, Coniston Road, Patchway Peartree Road, Bradley Stoke 
Coniston Road, Patchway Webbs Wood Road, Bradley Stoke 
Former Filton Airfield – New East of Harry Stoke – New 

East Fringe of Bristol Urban Area

Town Centres

Kingswood Staple Hill 
Hanham Downend 
Emersons Green  

Local Centres

Baugh Gardens Oldland Common Village 
Burley Grove Poole Road, Soundwell 
Cleevewood Road, Downend Pound Road, Kingswood 
Dibden Road, Mangotsfield Quakers Road Parade, Downend 
Ellacombe Road, Longwell Green Soundwell Road, Kingswood 
High Street, Hanham Station Road, Kingswood 
Holly Hill Road Stockwell Drive, Mangotsfield 
Longwell Green Parade, Bath Road Tibberton, Kingswood 
Mangotsfield Village (St James Place, St James’s St, Cossham St) Warmley Village (Deanery Road, High St, Stanley Rd, Tower Rd North) 
Memorial Road, Hanham Westbourne Road Parade, Downend 
New Cheltenham Road, Kingswood Westcourt Drive, Oldland Common 
Newton Road/School Road, Cadbury Heath Westons Way, Kingswood 
North Street/Pleasant Street/Victoria Street  

Yate and Surrounding Areas

Town Centres

Yate Chipping Sodbury 

Local Centres

Lower Stone Close, Church Road and Woodend Road, Frampton Cotterell Bradley Avenue, Winterbourne 
Flaxpits Lane, Whitegates and high Street, Winterbourne Park Avenue, Winterbourne 
Abbotswood Shopping Centre Cranleigh Court Road 
Brimsham Park, Yate Firgrove Crescent 
Heron Way Westerleigh Road Stores 
Wellington Road Ladden Garden Village – New 

Thornbury

Town Centre

Thornbury

Local Centre

Oakleaze Road

Town Centres and Primary Shopping Areas

The extent of Town Centres and Primary Shopping Areas are defined on the Policies Map. We are consulting on revised boundaries as part of the Phase 3 consultation; these will be altered and updated in the final version of the plan.

Primary Shopping Areas are the defined area where retail development is concentrated and expected to be located in the first instance when over a certain size. Retail development means development falling within Use Class E(a).

Main Town Centre uses, Edge of Centre and Out of Centre

Main Town Centre uses are defined in National policy as: Retail development (including warehouse clubs and factory outlet centres); leisure, entertainment and more intensive sport and recreation uses

(including cinemas, restaurants, drive-through restaurants, bars and pubs, nightclubs, casinos, health and fitness centres, indoor bowling centres and bingo halls); offices; and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).

Edge of Centre is defined in National policy as:

  • For retail purposes, a location that is well connected to, and up to 300 metres from, the primary shopping area.
  • For all other main town centre uses, a location within 300 metres of a town centre boundary.
  • For office development, this includes locations outside the town centre but within 500 metres of a public transport interchange. In determining whether a site falls within the definition of edge of centre, account should be taken of local circumstances.

Out of Centre is defined in National policy as: A location which is not in or on the edge of a centre but not necessarily outside the urban area.

Creation of New Town and Local Centres

Proposals for new town or local centres should include supporting information on its anticipated catchment, the scale and format of the uses proposed within it, and analysis of any similar provision and/or overlap within the nearest existing town centres. To ensure viability in early stages of their establishment, information should also be included on the proposed marketing strategy and a timetable for their implementation.

Impact Assessments

Small scale retail development is considered in South Gloucestershire to be development below 350m². Large scale retail development is considered to be anything above 350m².

National policy requires an impact assessment for retail and leisure development outside of town centres which is above a proportionate, locally set threshold, or where there is no local threshold a default threshold of 2,500m² gross floorspace. In South Gloucestershire town centres are relatively small and experiencing reduced vitality, a dominance of out-of-town floorspace, particularly for retail can have significant impacts on our designated town centre and local centres. Consequently, smaller developments can, on their own or cumulatively, have a significant impact on existing centres. The locally set thresholds therefore reflect this and are applicable not only to new development but also section 73 Applications and variations to S106 agreements which may seek amendments to existing permissions which necessarily restrict the level and type of goods that can be sold.

Definition of Effective Marketing

The site must be proactively marketed, using a range of media, for a minimum period of 12 months by a professional agent having appropriate commercial experience. A longer marketing period may be necessary in some circumstances, such as during economic recession and/or disruption resulting from national/ international events. The sale/ lease/ rental price sought must be shown to be reasonable over full duration of the marketing period.

Question

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Strategic and Major Site Delivery Policy

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

Areas safeguarded for standalone wind energy development are defined on the Policies Map.

Purpose

The NPPF requires LPAs to maintain a 5-year housing land supply. Large strategic development sites can take many years to implement given the number of interested stakeholders, complexity and significance of issues such as infrastructure delivery that accompany them. A number of such sites are now under construction in South Gloucestershire at places such as Lyde Green, Harry Stoke, Charlton Hayes, North Yate and Cribbs Patchway/Filton Airfield. The council therefore now has substantial experience in large site delivery. Similarly, the importance of such strategic sites to housing supply in creating successful new mixed and balanced communities for the long-term and the inherent delivery challenges have been recognised at a national level by organisations such as the TCPA who have published documents including, ‘Building Successful New Communities’ and ‘Delivering New Communities (A Technical Guide to Project and Programme Management for Local Authorities’). Therefore, in order to improve outcomes and speed delivery it is vitally important that this learning is captured and applied in a consistent away across the new strategic development sites. The policy therefore sets out a series of critical generic requirements applicable to proposed development at x, y and z, but may be tailored accordingly to smaller allocations and development proposals that may come forward during the life of the plan as appropriate.

Policy wording

In order to deliver high quality and cohesive communities at Strategic Development allocations x, y and z, landowners and developer partners will be required to:

  1. Agree a clear vision, programme management plan and governance structure.
  2. Plan the allocation in a comprehensive manner, working jointly with relevant landowners and developers including registered providers and self and custom build enablers, to ensure land value and infrastructure costs are shared fairly and proportionately.
  3. Agree the composition, administer, and promote liaison via a stakeholder engagement group that will meet regularly through the design and construction phases.
  4. Develop a communication strategy setting out benefits of the scheme, including a wider community engagement strategy from concept to final delivery.
  5. Undertake pre-app engagement and Design Review of the emerging masterplan and Affordable Housing masterplan, initial development parcels, key parts and aspects of the scheme, including Design Code testing prior to 1st R/Ms approval.
  6. Provide an Affordable and Self and Custom Housing masterplan(s) and delivery schedule(s) to ensure that they are delivered in step with the market housing over the course of the development.
  7. Depending upon the vision and particular objectives of the scheme utilise a nationally recognised accreditation standard(s) for example, BREEAM Communities and Building with Nature.
  8. Set out, consult on and agree long-term community development and stewardship arrangements in partnership with the council and relevant stakeholders including registered providers.
  9. Provide topographical and earthmoving information at outline application stage to demonstrate strategic green infrastructure, drainage and public open space requirements function and fit as part of the master planning process.
  10. Provide ecological and landscape and play benefits early in the construction phase.
  11. Work with partner organisations to realise necessary supporting infrastructure in a timely way in step with housing delivery and additional infrastructure and Affordable Housing funding throughout the lifetime of the construction phase.
  12. Include review mechanisms to ensure sustainable construction, climate mitigation and adaptation objectives keep pace with new regulations, technology, national and local policy objectives.
  13. Provide opportunities for SME housebuilders, custom and self-builders.
  14. Provide a community, retail and employment strategy that integrates opportunities and floorspace across the scheme for a range of uses, types and scale of businesses including marginal activities such as start-ups, SMEs and charities, in the short (during the construction phase) and long-term.
  15. Agree and implement a construction and post construction monitoring and reporting regime to ensure compliance with required standards and feedback of resident’s satisfaction.

Promoters of other major development sites should carefully consider and agree at pre-application stage with the council which of the above requirements are appropriate and should form part of any subsequent planning application and permission.

Supporting text

  1. Large scale new communities are complex, long-term projects that require commitment across the political, economic, corporate and planning divisions of the council as well as clear lines of responsibility both at the council and developer partner(s). Success will also in large part depend on robust programme management so that the various elements can be holistically planned and delivered, and a strong shared vision of the new community in order to clarify priorities, measure progress against and thereby ensure that the ambition is achieved. A clear programme should as a minimum identify milestone dates and key stakeholders. Appropriate governance, in terms of the composition, responsibilities and regularity of meetings of personnel on both sides can then be identified and agreed. The vision, programme and governance structure should be agreed prior to outline approval. A Planning Performance Agreement (PPA) will be integral in creating and structuring a collaborative approach as well as identifying necessary additional resources and expertise required by the council to assist deliver the new community in a timely way.
  2. Complexity and thereby risk and time can be reduced if the number of delivery partners is minimised. The council will therefore require that all key landowners and developers, including registered provider partners and self and custom build enablers where appropriate, work together to equalise land value, master plan in a comprehensive way and share infrastructure costs proportionately. The vision and governance arrangements should reflect this comprehensive approach.
  3. People and community should be central to the vision of a new place. Community involvement can be undertaken in many ways but critically it should be ongoing, regular, honest and open. Clear scope and defined objectives can assist this process. Developer partners will therefore be required to set out, agree and administer a clear community engagement process, including regularised stakeholder engagement through the life of the scheme to final completion. Stakeholder engagement arrangements during the pre-construction phase should be identified in the PPA and post outline approval via the s106.
  4. The benefits of a new development to the wider community are often not widely shared leading to a negative view of new housing. Developer partners will therefore be required to set out and deliver a communication strategy beyond the usual pre-application and outline application engagement phase. It should be agreed at outline planning application stage and promote delivery of infrastructure such as Affordable Housing and new sustainable transport options.
  5. The NPPF requires that Local Authorities have access to tools such as design review panels to assist promote high quality design. Design review is best carried out early in the design process but can also be used to test emerging design codes and subsequent reserved matters for key parts of the development such as the first residential phases, local centre and strategic POS areas. Formal pre-app advice services should similarly be used to test emerging proposals. Developer partners will therefore be required to agree and set out, through the PPA and subsequent Design and Access Statement at outline stage, when design review and pre-app services will be utilised.
  6. A specific Affordable Housing masterplan is required to set out where the Affordable Housing will be located. This is to ensure that each phase of the development delivers an appropriate tenure balance that will result in a mixed and balanced community, and that cluster sizes and other detailed requirements are met. An Affordable Housing delivery schedule is required so that the proportion of Affordable Housing planned for each phase can be monitored. This is to ensure that Affordable Homes are not deferred until late in the construction period, which would delay meeting need, and potentially lead to overly large clusters and threaten deliverability. The delivery schedule must be updated alongside each reserved matters layout application for respective parcels of development. Equally, the site and phasing for the self and custom build housing must be identified on the masterplan. Custom and self-build developments are best delivered in a single or large cluster(s) in a location(s) that enables delivery separate to the main housing development. This is to enable safe access for the custom and self-builders or sale to a custom build enabler to deliver the dwellings on behalf of the custom and self-builders and the master developer.
  7. Accreditation to an independent development standard is a further way to ensure design quality. The council will therefore expect at outline application stage and via condition or s106 that the master developer seeks to achieve an appropriate nationally recognised accreditation as a means to demonstrate high quality design.
  8. Community development and stewardship arrangements are critical components of delivering long-term sustainable communities. Community development should be considered from the outset and agreed via the outline application, to ensure early residents are supported in terms of accessing services and social cohesion. Some Affordable Housing providers have experience in providing such support and or community development and should be part of long-term stewardship arrangements. Such support should not therefore be onerous if considered early and carefully with possible partners. The management and maintenance of community facilities, communal and public areas should equally be carefully considered and can be organised in a variety of ways. Basic management company arrangements may be acceptable for small areas of communal landscaping, but facilities and public open space that may also attract use by the wider surrounding existing population will require much more care and thought in terms of management arrangements such that the burden doesn’t fall unfairly on the new residents. Different stewardship models and pump priming arrangements should be investigated and considered with key stakeholders such as the council, local parish or town council and prospective registered provider partners before agreeing on the most appropriate arrangements. Models that ensure community involvement and potential ownership are preferred. See Policy X – Stewardship Arrangements.
  9. Time and again insufficient attention is paid at the feasibility stage and pre-app stage to the space required to accommodate strategic green infrastructure, drainage and formal public open space areas leading to significant delays during the planning application process. Common mistakes during the pre-application master planning / design phase include failure to consider the impacts of or accommodate slopes and insufficient space provided to buffer existing green infrastructure and proposed new sports, play areas and SUDs features. This can lead to hard usually unacceptable and over engineered solutions being put forward at the detailed design phase, leading to time delays and the loss of both existing vegetation and development areas potentially undermining the original vision and ambitions of the scheme. Developer partners should therefore take steps and care to demonstrate that such requirements can be accommodated appropriately prior to and at the outline application stage.
  10. The health and wellbeing benefits of access to green space are now well established. ‘Landscaping’ and access to play is however often left to the end of the development process. This can leave large new developments appearing stark and denuded of vegetation and play opportunities for many years during the construction phase and after. Strategic areas of open space that can be planted up early, potentially at the very start of the development should therefore be identified and delivered as soon as possible. This will lead to benefits for new and existing nearby residents and wildlife, but no doubt also assist market the development to prospective customers. These areas for early planting and play should be identified at outline stage and agreed via condition or s106.
  11. Supporting infrastructure too often lags behind delivery of the housing. Developers and their infrastructure partners need to agree timely triggers for delivery and work hard to ensure these are met to ensure infrastructure is delivered in step with the dwellings. Large scale new developments also often have very high infrastructure costs that can impact on viability and ultimately the amount of Affordable Housing. This can undermine local support for such projects from the outset. New funding opportunities however may arise during the construction phase as national and sub-regional imperatives to speed delivery and/or deliver more affordable homes change. Mechanisms should therefore be considered and agreed at outline stage to promote joint working to enable any such opportunities to be investigated and bids to be made to maximise affordable housing and the speed of infrastructure delivery.
  12. Similarly, technology and regulatory standards are likely to continue to evolve as the necessity to meet climate change objectives continue to step up. Mechanisms should therefore be considered and agreed at outline stage to ensure and enable that the most up-to-date standards and technology are incorporated as the development builds out.
  13. In recent decades the number of housebuilding companies has been declining. The diversity of new housing has also declined with many of the large housebuilders providing extremely similar ‘product’ and therefore little customer choice. The Letwin Review subsequently identified the need to maximise diversity in local housing markets as a key means not only to provide more choice but also to speed delivery of large-scale new communities, by ensuring ‘product’ caters for as wide a possible cross section of potential customers so increasing sales rates. It is required therefore that opportunities for small and medium sized housebuilders, such as by providing a variety of parcel sizes, as well as self and custom build opportunities should be provided for sale on these new communities. SME and self-build parcels should be agreed at outline stage.
  14. Recent years have seen significant changes away from traditional forms of retail and employment uses to more online and footloose activities. However, integrating a range of uses across a new community remains critical to providing walkable and vibrant places. Indeed, more homeworking for instance means that local amenities and services become more important. These, often small-scale activities, can also sit comfortably side by side with residential properties. As residential property values have also risen outpacing yields from some employment and retail activities the economic incentive to provide for such activities is increasingly challenging. Proposals and permissions that for instance provide ‘up to’ xm2 of retail and employment space now appear out-dated and not fit for purpose, leading to disillusionment with the development, as promised maximum square footage of such space do not materialise. Careful consideration is therefore required as to how more homeworking and marginal economic activities can be supported and integrated into new developments, as well as the usual convenience retail and commercial operations. Minimum floorspace requirements should be set, owner and stewardship models put in place to enable the early and long-term provision of a range of flexible space integrated into central hubs and more generally across the new community. Pop-up and meanwhile uses should also be provided during the construction phase to help promote such economic activity. Some Housing Associations have experience in regeneration and foundation economy delivery that could be explored to assist deliver other non-residential uses. A strategy and partners should be set out and agreed at outline stage.
  15. The difference between stated high ambitions and eventual outcomes (the performance gap) is a genuine problem and again can lead to disillusionment and opposition to new development. There are many reasons for this from poor regulation and communication to lack of resources, skills and staff turnover during the life of a project. Agreeing realistic ambitions and good governance can go some way to addressing the issue, but good governance requires good information. Measures should therefore be agreed, and resources put in place to collect some key indicators and regularise monitoring activities. These key indicators may vary through the life of the new development. Results should be shared openly and honestly with all stakeholders. Indicators and monitoring activities could range from regularised surveys of tree protection fencing to new resident satisfaction surveys. Better communications and regularised monitoring of activities will also lead to reduced potential for enforcement and remediation activities as well as improved relations between all parties. A monitoring strategy should be agreed at outline stage.

All of the issues above should be reflected appropriately in the respective plans, conditions and legal agreements of the new communities to ensure their delivery.

Note: The council recognises that promoters of strategic scale sites that are part of the emerging preferred spatial strategy will need to develop proposals further into the new Local Plan regulation 19 stage in order to assist formulate site allocation policies, clarify deliverability issues for the local plan inquiry and prepare for a planning application. This is likely to involve preparing technical evidence, vision, concept and master plans, and community led design engagement. This will require input and support from the council. The council will therefore seek to agree a ‘Strategic Site (promoter) PPA’, in order to ensure resources are available for this critical part of the process. A further PPA(s) will then be required as suggested in the policy to support post adoption/planning application stages.

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Stewardship Arrangements

Existing policies

Which adopted Core Strategy or Policies Sites and Places (PSP) policy would eventually be replaced:

This is a new supplementary policy.

Purpose

The NPPF requires strategic policy making authorities to plan for large scale development and in so doing ‘set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City principles)’. The National Design Guide contains ten characteristics for well-designed places, including one on ‘Lifespan’ in which it states that, ‘well designed places, buildings and spaces are: Designed and planned for long-term stewardship by landowners, communities and local authorities from the earliest stages; Robust, easy to use and look after, and enable their users to establish a sense of ownership and belonging, ensuring places and buildings age gracefully’. Building for a Healthy life refers to the need for well-considered long-term robust management and stewardship arrangements whether public or private.

Over the last couple of decades, primarily due to public sector resource and development viability issues, it has become common practice for public open space in new developments to be transferred to and managed by private management companies (manco’s). The practice is now well established and maturing such that there is emerging best practice and a variety of models from simple profit-based companies funded purely via resident’s management charges to trusts and charitable organisations with strong community representation and multiple funding sources. Different models including local authority or registered provider management and maintenance may thus be appropriate in different circumstances.

The policy is therefore necessary to meet NPPF requirements to set clear expectations for how large-scale development can be maintained. As different models may be appropriate in different circumstances it is not possible or indeed wise to prescribe one approach, but ensure that stewardship arrangements are considered early, different models and approaches assessed, and professional advice engaged to assist select the most appropriate way forward. What is clear though is that there are a number of themes that need addressing, namely:

  • Ensuring robust resident participation in decision making (in perpetuity).
  • Transparency of decision making and funding.
  • Robust clear, equitable and sustainable funding arrangements.
  • Absolute clarity of which adopting authority is responsible for what, and
  • A consistent approach across all phases of the development.

Policy wording

To deliver high quality landscaping and public realm in perpetuity all major development that includes new areas of open space and green infrastructure should include for approval at outline or full application stage a management and maintenance strategy that clearly details future ownership, the responsible maintenance body, a long term financially sustainable maintenance plan and arrangements for resident input into objectives, scrutiny of accounts and representation on the management entity board. With regard to Strategic Development Allocations x, y and z, landowners and/or their developer partners including registered providers and self and custom build enablers will, in addition, be required to:

  1. Consider management and maintenance issues at the outline, master planning, and design code stage(s) and provide an assessment of the potential options for estate stewardship entity bodies. They shall jointly agree the appropriate model objectives and principles with the council prior to determination of the outline planning application. Where feasible community management of the assets will be preferred.

    Where a public authority or community body is not the agreed stewardship entity:
  2. Ensure the strategic and communal public open space areas and amenities are controlled by a single estate stewardship entity and each developer/landowner contributes equitable and proportionate funding.
  3. Ensure that the estate stewardship entity board includes representatives from residents of the new development of all tenure types and that residents have a legal right to take a controlling interest in the entity.
  4. Ensure that as appropriate local authority, parish and/or town council, registered providers, Extra-care, self and custom build enablers, C2 and BTR operators, school academy trusts as well as any on site energy, commercial, and other interested parties liaise and work with the stewardship entity board.
  5. As a minimum, provide an endowment and a strategy for a range of income streams to fund the management and maintenance of areas of open space, facilities and amenities that will attract non-resident users.
  6. Provide a regular onsite management entity presence, and
  7. Facilitate integrated governance, community development, stakeholder and resident group arrangements.

Supporting text

The NPPF requires strategic policy making authorities to plan for large scale development and in so doing ‘set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City principles)’. The National Design Guide contains ten characteristics for well-designed places, including one on ‘Lifespan’ in which it states that, ‘well designed places, buildings and spaces are: Designed and planned for long-term stewardship by landowners, communities and local authorities from the earliest stages; Robust, easy to use and look after, and enable their users to establish a sense of ownership and belonging, ensuring places and buildings age gracefully’. Building for a Healthy Life refers to the need for well-considered long-term robust management and stewardship arrangements whether public or private.

Over the last couple of decades, primarily due to public sector resource and development viability issues, it has become common practice for public open space in new developments to be transferred to and managed by private management companies (manco’s). The practice is now well established and maturing such that there is emerging best practice and a variety of models from simple profit-based ltd companies funded purely via resident’s management charges to trusts and charitable organisations with strong community representation and multiple funding sources.

Stewardship arrangements are critical components of delivering long-term sustainable communities. The management and maintenance of community facilities, communal and public areas should be carefully considered and can be organised in a variety of ways. Basic management company arrangements may be acceptable for small areas of communal landscaping (block manco’s), but facilities and public open space that may attract use by external/non-resident populations will require much more care and thought such that the burden doesn’t fall unfairly on the new residents. Different models including local authority or registered provider management and maintenance may be appropriate in different circumstances.

In all circumstances where major development includes areas of open space (hard or soft) and green infrastructure a clear and accurate plan showing all areas of the site with the respective managing body and LEMP (Landscape and Ecology Management Plan) should be provided alongside details of the managing agent, funding arrangements (split between resident charges, income from assets and endowment), resident representation and scrutiny mechanisms, including availability of accounts. These arrangements should be carefully set out and clearly highlighted in articles of association and manco resident introduction packs, which should be consistent across all tenure types. They should include positive and pro-active steps to engage with and provide residents of all tenures with a controlling interest on the management board and in decisions in respect of charge setting. Design should ensure these public places and spaces are attractive, robust, easy to use and look after.

With respect to the strategic development allocations, the following additional considerations are required:

  1. It is assumed that small areas of communal open space and landscaping associated with apartment blocks and clusters of houses (e.g. in parking courts) will be managed by private management entities. Larger areas of public open space, such as parks, pitches, play areas, street trees and verges, strategic green infrastructure and any non-residential uses (community buildings, pavilions, changing facilities and potentially some commercial and retail assets) will be managed by an ‘estate stewardship entity’. As such, the most appropriate legal and organisational structure should be considered and agreed at outline stage. This could include public adoption (district or parish council), registered charity, registered provider, social enterprise, land trust or private ltd company. Models and organisations that provide for community involvement in the management of assets should be given a high priority in these considerations.

    As part of considering the most appropriate stewardship model it will be necessary to consider and agree the objectives and principles of any entity. The context and nature of the development (mix of uses, type and quantum of open space and new community facilities) will influence such considerations. Environmental, social or commercial priorities may emerge which, when combined with funding options will influence the objectives and principles of the stewardship entity. These objectives and principles should be clearly stated before engaging with prospective delivery organisations and tendering contracts to ensure potential delivery partners understand what is required.
  2. On sites with multiple developers and or landowners respective parties must work together to put in place a single estate stewardship entity to ensure clarity, fairness and economies of scale for residents.
  3. It is critical that residents paying management fees are given a say in the operation of the management entity and charge setting, and are given a legal right to take control of the entity if they so wish. Management schemes and articles of association should clearly specify what these rights are and how they will operate in practice.
  4. New communities inevitably have a range of stakeholders. The local authority may continue to adopt roads and collect waste, the parish or town council may wish to continue to receive a precept and therefore play a role, and other organisations such as registered providers and school academies often perform important community development functions as well as provide communal facilities. It is important therefore that these organisations are engaged with on a regular and ongoing basis, via the estate stewardship entity board, to ensure smooth working relationships and better outcomes for all concerned.
  5. To greater or lesser extent depending on the size and nature of new open space and facilities and the local context / proximity to existing communities, the new amenities provided will attract use by non-residents. Very careful consideration is therefore needed to ensure that new residents are not left unfairly paying for the management and maintenance of the new community’s amenities. Alternate and/or additional funding streams must therefore be considered and put in place to limit the burden on new residents where this may be the case, especially those in affordable housing. This could include income from assets (e.g. rental charges for use of pitches, halls, public areas and commercial property), lump sum management investment funds/endowments and other sources of income such as grants, charitable donations and contributions from other stewardship partners such as the parish council.
  6. Ensuring regular onsite presence via an estate officer and/or office can greatly increase resident engagement and participation in management activities, providing a friendly face, quick and direct contact for residents and any issues that may arise as well as better oversight of the new community and service for residents.
  7. There is evidence that large new communities are stressed communities and require additional agency support for early occupiers and throughout the construction period. Without suitable support problems can arise which impact adversely on residents, developers, the local authority and other agencies resulting in additional cost and negative publicity. Governance provisions and the role and resourcing of community development measures, stakeholder and resident groups should therefore be considered carefully alongside estate stewardship arrangements, ensuring they complement and reinforce one another. These aspects should be agreed at outline stage.

All of the issues above should be reflected appropriately in the respective plans, conditions and legal agreements to ensure their delivery. A Supplementary Planning Document will be produced that will set out the various stewardship entity options / models and the context / scenarios where they would be most appropriate as well as model clauses for articles of association and s106 agreements.

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