| | CPRE GLOUCESTERSHIRE BRANCH
| Policy Statement Draft RSS EIP CPRE Glos Response |
DRAFT REGIONAL SPATIAL STRATEGY FOR THE SOUTH WEST EXAMINATION IN PUBLIC: APRIL - JULY 2007
RESPONSE OF CPRE GLOUCESTERSHIRE TO THE PANEL REPORT
CPRE Gloucestershire Branch responded to the consultation on the draft Regional Spatial Strategy (RSS) and participated in the Examination in Public. We have read the Panel Report and make the following comments on a number of key aspects of the report. There are aspects we welcome, there are aspects we support but there are some aspects that cause us great concern.
Aspects that we welcome
Considerations of sustainability, and particularly the closer alignment of new housing and employment opportunities and reducing the need to travel, point to a focus of growth on Gloucester and Cheltenham. We welcome the support of the Panel to that approach and to avoiding dispersed patterns of development.
Effective planning of the Gloucester and Cheltenham areas will require close working between Gloucester City, Cheltenham Borough, Tewkesbury Borough and Stroud District Councils. We welcome the recommendations for co-ordinating LDD formulation and would support the idea of a single Development Plan Document, if this is feasible.
There is a welcome recommendation about increasing the delivery of affordable housing across the region with a raising of the target from 30% to 35% of new houses, to be delivered through Housing Corporation funding and through an increased capture of developer contributions by reducing the site size thresholds.
Aspects we support
In considering Green Belt areas and urban extensions, the Panel argues that the balance of advantage in terms of sustainability lies with extensions on the inner edge of the Green Belt rather than substantial further dispersed development beyond the Green Belt. In terms of development around Gloucester and Cheltenham, this is a view that CPRE Gloucestershire Branch has long supported and argued for in relation to the earlier review of the Gloucestershire Structure Plan, but with the important caveat that urban extensions should only be considered when all major brownfield redevelopment opportunities have been exhausted.
We are pleased to see the proposal for an additional policy (C2) covering development in the open countryside, although we will need to ensure that the policy is tightly drafted in the revised RSS and not open to miss-interpretation. Only development which necessarily requires a rural location should be permitted.
Aspects of concern
In our view, the Panel has placed undue importance on the 2003 household projections. Coupled with a high aspirational rate of economic growth over the 20 year period of the plan, this has produced recommendations for a 40% increase in housing delivery across the region compared with that required in the current RSS, RPG10. We have moved from a measured approach to development in the draft RSS built firmly around the principles of plan, monitor and manage, to an approach built around projections which can only be described as predict and provide and which does not adequately take into account environmental and other constraints or the ability to deliver.
To meet the housing targets, the Panel proposes pursuing greenfield land releases and brownfield site development together and any question of a sequential approach to development is rejected. Indeed, the Panel goes further and rejects the policy that development of previously developed land should be an over-riding priority. Should there be an economic slow down it seems to us inevitable that developers will pursue the easier greenfield development options and it would be come increasingly difficult to achieve regeneration imperatives. We will continue to press for an ordered approach to development which prioritises redevelopment of brownfield sites. We will also press for a firm target for brownfield site development above the 50% target in the draft RSS which the Panel said should not be viewed as a target at all, but simply a figure for monitoring purposes.
The higher housing numbers proposed and the recommendation that delivery be speeded up risks “planning by appeal” until the District Councils have completed their Core Strategies under the Local Development Framework process. There should be no release of sites within “areas of search” in the RSS until the LDF process has been completed.
We are concerned that the Panel has rejected additions to the Green Belt south of Gloucester and to the north of Bishops Cleeve on the grounds that they are not justified. We agree that Green Belt designation should only be used where it is important in delivering the objectives of the strategy and there must be sound planning reasons. Green Belts bring certainty. There remains a need to prevent the further southward extension of Gloucester beyond current commitments on the basis of sustainable development patterns and environmental considerations. Green Belt designation would provide for that requirement and should also aid regeneration within the city, one of the five purposes of Green Belts.
The housing figures for Gloucestershire over the 20 years of the Plan are increased from 48,600 to 56,400, an increase of 7,800 (16%). The draft RSS allocated 62% of the housing to the Gloucester and Cheltenham areas and the remainder (38%) to the rest of the County. The recommendation is that that split should be retained. For Gloucester and Cheltenham the higher housing numbers have resulted in additional development locations being proposed. For the rest of the County it is not clear how the additional numbers are to be accommodated. We are concerned that there is little recognition of the need for restraints for environmental reasons and no acknowledgement of the special policies which apply in those parts of the county designated as AONB – the Cotswolds, Wye Valley and Malvern Hills.
Finally, flooding. The Panel is very complacent on this issue, simply taking the view that development in the areas recommended is not considered to be at risk from flooding and that more detailed assessment should be left to the LDFs.
February 2008