Our Key Objections and Concerns
- Loss of Greenbelt land and prime agricultural land
- Too Many Houses – Volumes have been based on old data - the need is not proven
- Abandonment of our Government’s Brownfield First Strategy
- Amenity and Health Reasons
- Inadequate transport infrastructure provision (including no improvement to M5 motorway junction 9) - serious impact on the surrounding area.
- Risk of Flooding
Below I include sections of our response to the JCS which gives me detail to our concerns and objection, and provide evidence to back them up. See here for the full document.
Loss of Greenbelt and Green Fields
Save the Countryside objects to the unnecessary breaching of the Cheltenham / Gloucester Green Belt at A5 and elsewhere in the JCS area.
If the recalculation of housing numbers is undertaken it will remove the need to use Green Belt land for urban extensions during the plan period.
Our Government, the Prime Minister, Eric Pickles and Nick Boles, have all at one time or another promised to save Green Belt land around the country – but this is as long as the land remains designated as Green Belt.
The JCS consultation document seems to duck such opposition to development on Green Belt land by proposing removal of the land from the designation. Save the Countryside objects to this as it appears to be a developer-led initiative for maximum margin generation on easier green field sites at the expense of the regeneration of our town centres.
Despite this proposed de-designation, JCS Policy S5 Green Belt claims that
“It will be protected from harmful development within its boundaries.”
This certainly does not match what is proposed.
Save the Countryside objects to the sheer scale of the proposed reduction in the Green Belt – over 20% of the land area to allow a proposed development of around 11 000 houses – one of the biggest incursions ever, with North West Cheltenham Urban Extension A5 with 4829 houses proposed being the biggest single JCS allocation.
So many policies are designed to protect Green Belts.
NPPF Core Planning Principles para 17 bullet 5 places importance on “protecting the Green Belts” around our main urban areas.
Under Section 9 of the NPPF, Protecting Green Belt Land, Para 79 states that “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open: the essential characteristics of Green Belts are their OPENNESS AND PERMANENCE.”
JCS para 3.33 describes “redrawing the Green Belt boundary [to] ensure that it would continue to deliver its primary function of preventing Gloucester and Cheltenham as well as Cheltenham and Bishop’s Cleeve from coalescing.”
The claim then that the primary function of the Green Belt is to prevent coalescence is a direct contradiction of the NPPF which, as above, states that the fundamental aim is to prevent urban sprawl. The housing estate urban extension planned for NW Cheltenham is itself the size of Bishop’s Cleeve, and with no Green Belt to prevent its own coalescence with Cheltenham, it can only be considered urban sprawl.
So although the A5 Green Belt meets all the purposes for Green Belts as described in the NPPF and JCS Policy S5 as it:
The JCS has decided, we believe wrongly, that over 1 square mile of it is non-functional.
Save the Countryside also objects to the inconsistency between Strategic Objective 4 bullet 4:
“…review the current Green Belt boundary whilst providing a long term permanent boundary”
and Policies SP1 and SP3 both of which refer to undertaking further Green Belt reviews within the plan period.
Too Many Houses
The Housing Target numbers were based upon Office of National Statistics (ONS) Interim Projections. The ONS considers that these are not the appropriate figures for this application. Revalidated projections published in 2012 are more appropriate. Using these figures brings the population projection down by about 24,000 persons and the housing projection down by about 10,000 houses.
This reduction can be seen as valid if one compares the Joint Core Strategy with the Bath and North Somerset Core Strategy. Even including some additional housing required by the Inspectorate after the first examination of Bath’s Core Strategy they are looking for a 16.7% increase in housing over 20 years.
The JCS envisages a 24.3% increase over 20 years. If a 16.7% increase were applied to the JCS, the housing requirement would reduce from about 33,200 houses to about 23,000.
A further validation of this need for recalculation comes from the fact that population in the JCS area only increased by 5.7% in the ten year period between the 2001 and 2011 Censuses. This gives a twenty year increase of 11.4%, hardly indicative of a need for a 24.3% increase in housing need over the next 20 years. It is essential that a recalculation of housing need in the JCS area be undertaken by the JCS team after discussion with the ONS about the most appropriate figures to use.
The JCS team at meetings with the public have promised our members to check the numbers - we expect that, when they are reviewed in light of the evidence that we have already provided based on our work with the Office of National Statistics, the JCS housing calculations will be revised.
Abandonment of Brownfield First Strategy
(Strategic Objective 6 bullet 1 Meeting the challenges of climate change, Policy SP1 Scale of new development)
Save the Countryside’s view remains in line with JCS Strategic Objective 6 bullet 1 which is “Making the best use of land by maximising the use of previously developed land”,
And the NPPF Section 11 para 111 which states: “Local planning authorities may continue to consider the case for setting a locally-appropriate target for the use of brownfield land.”
It is our view that LPAs not only may, but should target brownfield land before permission is given for any Greenfield development.
Save the Countryside is entirely against the statement in Para 3.31 of the draft JCS that
“It is anticipated that the majority of development on the urban extensions and strategic allocation will be started within the first part of the plan period”.
Front-loading of this sort will unnecessarily blight our countryside. Much more rational is the proposal in Policy SP1 for monitoring and a 5-year review of the appropriate level of new homes.
Amenity and health Reasons
One of the main reasons which has been claimed for dismissing this area as non-functional Green Belt and therefore supposedly eligible for development is as follows: it lacks the requisite openness (see Amec Green Belt Review for the JCS). Various of the other JCS reports* add to this dismissive picture but incidentally crucially acknowledge the following detriments to amenity: the M5 runs nearby, the site is otherwise bounded by the busy A4019, Kingsditch superstores, Swindon Village, the railway and – significantly – waste processing sites to the north.
( * Some of the conflicting reports: Broad Locations Report, Draft Sustainability (Integrated) Appraisal Report, Strategic Allocations Report, Entec Urban Extension Boundary Study.)
Surely the 3 Districts would be wilfully contravening their own JCS draft Policies C6 Supporting healthy lifestyles and wellbeing and Strategic Objective 9 bullet 4 (not to mention NPPF Core planning principles para 17 bullet 12 and Section 8) – if they (and Gloucestershire County Council who own much of the land) progressed a plan requiring 11 000+ residents, 20% of them children, to live in the 4829 dwellings proposed,
Risk of Flooding
Another factor which suggests that to build on A5 would be unsuitable is the flood risk from both fluvial and pluvial water sources.
The Strategic flood Risk Assessment level 2 shows significant areas within the planned North West Urban extension area as high surface flooding risk, due to the watercourses in the area predominantly the River Swilgate, Hyde Brook & Leigh Brook. The map extracted from this document demonstrates the watercourses and highest flood risk.
A further set of maps is due to be issued by the Environment Agency with new details of surface water run-off. Unfortunately these may not be available before the end of the consultation process but Save the Countryside wish to note that there may be further adverse impacts on the sustainability of any development proposed for Area A5.
Land to the north west of Cheltenham where the NW Urban Extension is planned is composed of heavy clay and there is regular surface flooding. Wingmoor Farm Toxic Waste landfill site is in this location precisely because the clay it sits on seals the tip. The land is regularly waterlogged. The fall to the river Severn (about 4 miles away) is slow. No amount of flood prevention works, ponds or sustainable drainage structures will prevent future flooding in this area because it is becoming evident that climatic conditions are changing and because the land is heavy clay. We have recent evidence of this in the floods of 2007.The soil has the same nature as that in the Tewkesbury area, where analysis has proved that Sustainable Urban Drainage systems (SUDs) are ineffective in areas of this soil type. This has been demonstrated in a report by the Severn and Avon Flood group entitled Building on the Flood Plain is Misguided (a definitive proof of evidence) of September 2008. www.nacratewkesbury.org.uk/Report%202008%20restricted%201.pdf
Save the Countryside objects to JCS Policy S2 bullet 3 which states that the sequential test even for land in Flood Zone 1 can be overridden and the exception test used. This means that a site can be developed even if it is deemed a flood risk.
It is totally irresponsible to consider the importance of the delivery of new sites over the risk of flooding.The photographic evidence shows some of the devastation caused within Swindon Parish alone where 4829 additional homes are suggested.
There should be no development on any greenfield area within the JCS boundary that may be liable to flooding in the future, fluvial or pluvial.
Large scale development on land such as identified for the North West urban extension will cause enhanced risk of flooding for existing housing and land, through water displacement as the soak away opportunity provided by the existing green fields is permanently removed through additional properties and roads built on the same land. This cannot be alleviated by temporary measures achieved by SUDS, whether or not the system is properly maintained as proposed in Policy S2 bullet 4.
Loss of Prime Agricultural Land
Despite all 3 local authorities, particularly Tewkesbury, having areas of agricultural land, the draft JCS virtually excludes agriculture as an industry, shown particularly in Vision, p11, where respect for the natural environment, but not the agricultural, is shown.
Save the Countryside objects to the fact that, despite assurances in JCS Strategic Objective 6 about “protecting the highest grade agricultural land”, the valuable strip of Grade 1-2 best and most versatile land along the A4019 at the southern edge of A5 will be wasted and disappear under business development and housing. Good 3A grade farmland will also be lost.
Similar to Objective 6, the NPPF in Section 11 para 110 states
“Plans should allocate land with the least environmental or amenity value”
and para 112: “Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land . . . should seek to use areas of poorer quality land in preference to that of higher quality”
The loss of this good quality land runs counter to Tewkesbury Borough Draft Local Plan Policies AGR1 – AGR7 which includes protection of the best quality land.
The proposed waste of a finite resource contrary to so many policies is yet another factor which leads us to the conclusion that A5 should be excluded from development.
Loss of Greenbelt and Green Fields
Save the Countryside objects to the unnecessary breaching of the Cheltenham / Gloucester Green Belt at A5 and elsewhere in the JCS area.
If the recalculation of housing numbers is undertaken it will remove the need to use Green Belt land for urban extensions during the plan period.
Our Government, the Prime Minister, Eric Pickles and Nick Boles, have all at one time or another promised to save Green Belt land around the country – but this is as long as the land remains designated as Green Belt.
The JCS consultation document seems to duck such opposition to development on Green Belt land by proposing removal of the land from the designation. Save the Countryside objects to this as it appears to be a developer-led initiative for maximum margin generation on easier green field sites at the expense of the regeneration of our town centres.
Despite this proposed de-designation, JCS Policy S5 Green Belt claims that
“It will be protected from harmful development within its boundaries.”
This certainly does not match what is proposed.
Save the Countryside objects to the sheer scale of the proposed reduction in the Green Belt – over 20% of the land area to allow a proposed development of around 11 000 houses – one of the biggest incursions ever, with North West Cheltenham Urban Extension A5 with 4829 houses proposed being the biggest single JCS allocation.
So many policies are designed to protect Green Belts.
NPPF Core Planning Principles para 17 bullet 5 places importance on “protecting the Green Belts” around our main urban areas.
Under Section 9 of the NPPF, Protecting Green Belt Land, Para 79 states that “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open: the essential characteristics of Green Belts are their OPENNESS AND PERMANENCE.”
JCS para 3.33 describes “redrawing the Green Belt boundary [to] ensure that it would continue to deliver its primary function of preventing Gloucester and Cheltenham as well as Cheltenham and Bishop’s Cleeve from coalescing.”
The claim then that the primary function of the Green Belt is to prevent coalescence is a direct contradiction of the NPPF which, as above, states that the fundamental aim is to prevent urban sprawl. The housing estate urban extension planned for NW Cheltenham is itself the size of Bishop’s Cleeve, and with no Green Belt to prevent its own coalescence with Cheltenham, it can only be considered urban sprawl.
So although the A5 Green Belt meets all the purposes for Green Belts as described in the NPPF and JCS Policy S5 as it:
- prevents Cheltenham sprawling,
- prevents it merging with other towns
- safeguards the countryside from encroachment,
- preserves the setting of historic Cheltenham and
- encourages town centre regeneration,
The JCS has decided, we believe wrongly, that over 1 square mile of it is non-functional.
Save the Countryside also objects to the inconsistency between Strategic Objective 4 bullet 4:
“…review the current Green Belt boundary whilst providing a long term permanent boundary”
and Policies SP1 and SP3 both of which refer to undertaking further Green Belt reviews within the plan period.
Too Many Houses
The Housing Target numbers were based upon Office of National Statistics (ONS) Interim Projections. The ONS considers that these are not the appropriate figures for this application. Revalidated projections published in 2012 are more appropriate. Using these figures brings the population projection down by about 24,000 persons and the housing projection down by about 10,000 houses.
This reduction can be seen as valid if one compares the Joint Core Strategy with the Bath and North Somerset Core Strategy. Even including some additional housing required by the Inspectorate after the first examination of Bath’s Core Strategy they are looking for a 16.7% increase in housing over 20 years.
The JCS envisages a 24.3% increase over 20 years. If a 16.7% increase were applied to the JCS, the housing requirement would reduce from about 33,200 houses to about 23,000.
A further validation of this need for recalculation comes from the fact that population in the JCS area only increased by 5.7% in the ten year period between the 2001 and 2011 Censuses. This gives a twenty year increase of 11.4%, hardly indicative of a need for a 24.3% increase in housing need over the next 20 years. It is essential that a recalculation of housing need in the JCS area be undertaken by the JCS team after discussion with the ONS about the most appropriate figures to use.
The JCS team at meetings with the public have promised our members to check the numbers - we expect that, when they are reviewed in light of the evidence that we have already provided based on our work with the Office of National Statistics, the JCS housing calculations will be revised.
Abandonment of Brownfield First Strategy
(Strategic Objective 6 bullet 1 Meeting the challenges of climate change, Policy SP1 Scale of new development)
Save the Countryside’s view remains in line with JCS Strategic Objective 6 bullet 1 which is “Making the best use of land by maximising the use of previously developed land”,
And the NPPF Section 11 para 111 which states: “Local planning authorities may continue to consider the case for setting a locally-appropriate target for the use of brownfield land.”
It is our view that LPAs not only may, but should target brownfield land before permission is given for any Greenfield development.
Save the Countryside is entirely against the statement in Para 3.31 of the draft JCS that
“It is anticipated that the majority of development on the urban extensions and strategic allocation will be started within the first part of the plan period”.
Front-loading of this sort will unnecessarily blight our countryside. Much more rational is the proposal in Policy SP1 for monitoring and a 5-year review of the appropriate level of new homes.
Amenity and health Reasons
One of the main reasons which has been claimed for dismissing this area as non-functional Green Belt and therefore supposedly eligible for development is as follows: it lacks the requisite openness (see Amec Green Belt Review for the JCS). Various of the other JCS reports* add to this dismissive picture but incidentally crucially acknowledge the following detriments to amenity: the M5 runs nearby, the site is otherwise bounded by the busy A4019, Kingsditch superstores, Swindon Village, the railway and – significantly – waste processing sites to the north.
( * Some of the conflicting reports: Broad Locations Report, Draft Sustainability (Integrated) Appraisal Report, Strategic Allocations Report, Entec Urban Extension Boundary Study.)
Surely the 3 Districts would be wilfully contravening their own JCS draft Policies C6 Supporting healthy lifestyles and wellbeing and Strategic Objective 9 bullet 4 (not to mention NPPF Core planning principles para 17 bullet 12 and Section 8) – if they (and Gloucestershire County Council who own much of the land) progressed a plan requiring 11 000+ residents, 20% of them children, to live in the 4829 dwellings proposed,
- some of them right alongside the noisy and polluting A4019 traffic with air quality problems, (the whole of Cheltenham is subject to Air Quality Management, M5 Junction 10 for instance exceeding recommended limits),
- some of them within metres of the noisy main line railway,
- some of them within 300 m of active long-term smelly and noisy landfill sites,
- some both of these,
- all of them within the EU directive REF NO advisory 3km no-build zone for the long term toxic waste site no-one mentions at Wingmoor Farm north east of the site and for which no JCS Health Assessment evidence document has been produced.
Risk of Flooding
Another factor which suggests that to build on A5 would be unsuitable is the flood risk from both fluvial and pluvial water sources.
The Strategic flood Risk Assessment level 2 shows significant areas within the planned North West Urban extension area as high surface flooding risk, due to the watercourses in the area predominantly the River Swilgate, Hyde Brook & Leigh Brook. The map extracted from this document demonstrates the watercourses and highest flood risk.
A further set of maps is due to be issued by the Environment Agency with new details of surface water run-off. Unfortunately these may not be available before the end of the consultation process but Save the Countryside wish to note that there may be further adverse impacts on the sustainability of any development proposed for Area A5.
Land to the north west of Cheltenham where the NW Urban Extension is planned is composed of heavy clay and there is regular surface flooding. Wingmoor Farm Toxic Waste landfill site is in this location precisely because the clay it sits on seals the tip. The land is regularly waterlogged. The fall to the river Severn (about 4 miles away) is slow. No amount of flood prevention works, ponds or sustainable drainage structures will prevent future flooding in this area because it is becoming evident that climatic conditions are changing and because the land is heavy clay. We have recent evidence of this in the floods of 2007.The soil has the same nature as that in the Tewkesbury area, where analysis has proved that Sustainable Urban Drainage systems (SUDs) are ineffective in areas of this soil type. This has been demonstrated in a report by the Severn and Avon Flood group entitled Building on the Flood Plain is Misguided (a definitive proof of evidence) of September 2008. www.nacratewkesbury.org.uk/Report%202008%20restricted%201.pdf
Save the Countryside objects to JCS Policy S2 bullet 3 which states that the sequential test even for land in Flood Zone 1 can be overridden and the exception test used. This means that a site can be developed even if it is deemed a flood risk.
It is totally irresponsible to consider the importance of the delivery of new sites over the risk of flooding.The photographic evidence shows some of the devastation caused within Swindon Parish alone where 4829 additional homes are suggested.
There should be no development on any greenfield area within the JCS boundary that may be liable to flooding in the future, fluvial or pluvial.
Large scale development on land such as identified for the North West urban extension will cause enhanced risk of flooding for existing housing and land, through water displacement as the soak away opportunity provided by the existing green fields is permanently removed through additional properties and roads built on the same land. This cannot be alleviated by temporary measures achieved by SUDS, whether or not the system is properly maintained as proposed in Policy S2 bullet 4.
Loss of Prime Agricultural Land
Despite all 3 local authorities, particularly Tewkesbury, having areas of agricultural land, the draft JCS virtually excludes agriculture as an industry, shown particularly in Vision, p11, where respect for the natural environment, but not the agricultural, is shown.
Save the Countryside objects to the fact that, despite assurances in JCS Strategic Objective 6 about “protecting the highest grade agricultural land”, the valuable strip of Grade 1-2 best and most versatile land along the A4019 at the southern edge of A5 will be wasted and disappear under business development and housing. Good 3A grade farmland will also be lost.
Similar to Objective 6, the NPPF in Section 11 para 110 states
“Plans should allocate land with the least environmental or amenity value”
and para 112: “Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land . . . should seek to use areas of poorer quality land in preference to that of higher quality”
The loss of this good quality land runs counter to Tewkesbury Borough Draft Local Plan Policies AGR1 – AGR7 which includes protection of the best quality land.
The proposed waste of a finite resource contrary to so many policies is yet another factor which leads us to the conclusion that A5 should be excluded from development.
