4/3: Gloucester and Cheltenham HMA sub-regional
strategy
In setting out
policies and proposals for the HMA sub-region, does the draft RSS adequately
deal with the following questions:
a.
Is the draft RSS
sufficiently clear about the spatial outcomes it is seeking in Gloucester and
Cheltenham in terms of their present and future regional and sub-regional roles
and their relationship with other parts of the HMA?
b.
Has the scale of
additional greenfield development been adequately justified against the likely level
of housing requirements and in particular the urban renewal opportunities
expected to be generated by the Gloucester Heritage URC Ltd?
c.
Is the contribution
from non-greenbelt extensions adequately justified and what is the status of
‘commitments’ referred to in SR11?
d.
Has sufficient
consideration been given to the impact of the lead-in times for the two large
urban extension areas on the required annual output for the Housing Market
Area?
e.
Have environmental
limits arising from matters such as flood risk and the protection of
environmental assets been adequately taken into account and in particular do
the proposals reflect the need to avoid development in the flood plain?
f.
Have infrastructure
considerations been adequately taken into account?
g.
Do the proposals
adequately reflect the need to reduce the need to travel, support the use of
public transport and minimise congestion?
h.
Are the proposed
modifications to the Green Belt adequately justified? and
i.
Does the draft RSS
set out adequate guidance on the provision of Green Infrastructure?
·
Endorsement of
the spatial approach proposed which is a continuation of the approach over the
last few decades but with a greater focus on Gloucester and Cheltenham which is
supported for sustainability reasons
·
Concern that
the scale of greenfield development proposed at Gloucester appears excessive in
the light of urban capacity studies which point to deferring further greenfield
development to the end of the plan period and only then after all brownfield
redevelopment opportunities have been taken up
·
Acceptance that
the scope for brownfield development at Cheltenham is more limited but concern
that a cautious approach to greenfield land releases should be maintained to
realise all regeneration opportunities
·
Opposition to
development of the “Leckhampton White Land” which is not justified
·
Concern over
potential flood risk in relation to Area of Search H which argues for careful
assessment of the scale, form and implementation of any development at this
location
·
Demand for
aggregates, and environmental constraints in Gloucestershire, requires the
issue of apportionment to be addressed
·
Concern that
further growth at Gloucester and Cheltenham will inevitably create demand for
more market housing within commuting distance and the need to restrain this
·
Impacts from
development at Gloucester and Cheltenham on the character of the adjacent rural
areas need to be addressed
·
A number of
detailed comments on infrastructure including opposition to the Gloucestershire
Parkway station proposal and suggestions for an alternative approach
·
Agreement that
the proposals reflect the need to reduce the need to travel, encourage public
transport use and reduce congestion,
but concern that the pace and scale of development proposed should not
be pursued unless there is certainty that transport improvements will be
delivered
·
Endorsement of
the conclusions of the Green Belt review but with the proviso that all
brownfield development opportunities are exhausted before any Green Belt land
is released
·
Endorsement of
the proposals for Green Belt extensions
·
Concern that
the local authorities should be required to develop proposals for Green
Infrastructure with a focus on securing greater public benefits from the Green
Belt.
Question a - Spatial
outcomes
1. We see a priority in the RSS as promoting more sustainable patterns of development making full use of existing infrastructure, prioritising re-use of previously developed land, linking new housing more closely to job opportunities so encouraging containment and reduced needs for travel, and providing new development where it can be more readily served by public transport. The RSS proposes to focus development on Gloucester and Cheltenham through urban renewal and reuse of developed land and in compact urban extensions if there is insufficient brownfield land. CPRE endorses this approach as right for the Gloucester and Cheltenham HMA, although we have concerns over some aspects of the detail.
2. This approach is a continuation of the approach to development in Gloucestershire over the past few decades with activity at Gloucester and Cheltenham benefiting from easy access to the strategic road and rail networks, complemented by the main market towns of Stroud and Tewkesbury and the Forest of Dean towns. The difference in the RSS is the greater focus on Gloucester and Cheltenham which CPRE supports on sustainability grounds.
Question b -
Additional greenfield development
3. At Gloucester, the draft RSS indicates a requirement for 575 dwellings a year over the plan period, a total of 11,500.
4. The Gloucester City Council Urban Capacity Study (June 2006) has looked at all potential sources of capacity, including previously developed land, vacant land and small and large sites. Adding in existing commitments of 5723 dwellings and allocations of 3125 additional dwellings through the LDF (para 3.10.3 of the Urban Capacity Study report), it is suggested that enough land is available within the City to meet housing needs until 2021. To ensure that brownfield sites and other “difficult sites” are in fact brought forward and urban regeneration opportunities are maximised, CPRE argues that further greenfield land releases for housing, including land within the proposed urban extension (Area of Search H), should not be agreed until all land identified above has been utilised.
5. The requirement for additional dwellings at Cheltenham is 425 a year, a total of 8,500 over the plan period.
6. An updated Housing Land Availability Assessment is awaited. The following comments are based on an assessment of the earlier Urban Capacity Study 2004 -2011. The area of this study was defined by the inner boundaries of the Green Belt and the boundaries of the Cotswolds AONB and included the unallocated land at Leckhampton (discussed in question c).
7. This study notes that new large site redevelopment opportunities are likely to be limited, such opportunities now being largely exhausted. Nevertheless, a potential for 1,700 dwellings is identified for brownfield sites during the period 2004 to 2011 and there are thought to be more opportunities for intensification of existing residential areas and changes of use on small sites. This suggests a cautious approach to any early release of greenfield sites for housing and the development of the proposed urban extension (Area of Search I) to ensure that brownfield site redevelopment opportunities are in fact realised.
8. Within both Gloucester and Cheltenham, opportunities should be sought for redeveloping the existing urban fabric at higher densities, while recognising the need to avoid “town cramming” and damaging the character of existing residential areas or losing local open space.
Question c Non-greenbelt extensions
9. We assume that the land referred to in this section is primarily the “Leckhampton White Land,” excluded from the Green Belt when that was defined. A succession of planning inquiries (Cheltenham Local Plan Inquiry 1993, Tewkesbury Local Plan Inquiry 2002/03, and the Cheltenham Local Plan Inquiry 2004/05) have clearly articulated the environmental significance of this area, its relationship to the Cotswolds AONB and the access opportunities it offers, and have concluded that large scale development would not be appropriate. This is set out in considerable detail in the Inspector’s Report into the Cheltenham Local Plan in 2005. CPRE fully endorses the conclusions of these various inquiries. It can see no justification for departing from this position and argues that the area should remain free from development in the long term and included within the Green Belt when the boundaries are reviewed in detail. Transport considerations also militate against major development at this location – see para 20.
10. In consequence, the 2000 dwellings that the RSS assumes to be built in non-greenbelt extensions to Cheltenham should be allocated elsewhere. If it still proves necessary to accommodate these dwellings at Cheltenham, Cheltenham and Tewkesbury Councils should examine whether further provision is possible within the existing built up area (informed by the Housing Land Availability Study in preparation) and whether additional provision might be more appropriately provided within the Area of Search I.
11. Our understanding is that the commitment in the Tewkesbury Borough Local Plan is conditional on the outcome of the RSS deliberations and so is not binding.
Question d - Lead-in
times
We have no comment at this stage.
Question e -
Environmental limits
12. Area of Search H, to the north of Gloucester, is dangerously close to the floodplain. A concern is not just the potential for flooding in the area of possible new development but risks of flooding to nearby existing properties as a result of reduced greenfield natural drainage and increased run off from hard surfaces. The scale, form and implementation of any development at this location will need to be carefully assessed in the light of these concerns.
13. CPRE has urged that Policy F1 Flood Risk needs to be strengthened:
Taking account of climate change and the increasing risk of coastal and river flooding, the priority is to:
- defend existing properties and locate new development in places with little or no risk of flooding (where possible deleted)
- protect flood plains and land liable to coastal flooding from all development (all added)
-
(delete the
reference to a sequential approach)
14. The scale of development proposed will create further demand for aggregates. Potential shortfalls in the supply of primary aggregates in Gloucestershire are acknowledged in the draft RSS. CPRE has made representations on the issue of apportionment, welcoming the acknowledgement and arguing for a clear methodology and procedure (including consideration of alternative options to identify the most sustainable way forward) for re-evaluation (paras 7.3.27 and 7.3.28). Subject to this consideration, there may be scope for some re-apportionment within the Region in respect of crushed rock. For sand and gravel there is an overall regional shortfall and there are questions as to whether crushed rock could be substituted for some sand and gravel usage and whether inter-regional solutions are necessary or appropriate. Maximum use should be made of recycled materials and secondary aggregates.
15. Increased job opportunities at Gloucester
and Cheltenham will inevitably create pressure for more development,
particularly for market housing, in the surrounding rural areas and within the
Cotswolds AONB. Policies for growth at
Gloucester and Cheltenham must be matched with policies for restraint of new
market housing in villages in the other districts in Gloucestershire and
elsewhere if additional short and longer distance commuting is to be avoided
and traffic movements contained.
16. There are also issues of impacts on the
character of the rural areas adjoining the SSCTs which need to be
addressed. The proposed extension of
the Gloucester and Cheltenham Green Belt will have the secondary benefit of
protecting the foothills of the Cotswolds AONB. Elsewhere, we have argued for special recognition of the Forest
of Dean as an area of regional landscape significance which is clearly of such
importance to merit designation as an AONB.
Question f - Infrastructure
considerations
17. Our main concern is with transport
infrastructure deliverability (See question g). We have a number of specific points relating to access to
Gloucester from the south, to the proposed urban extensions, and to the
proposed Gloucestershire Parkway station.
18. It is hoped that the opening of the Gloucester South
West Bypass (but supported
subjectby to demand management measures, see
below) will alleviate access problems
to Gloucester City from the south which will be made worse by the committed
housing developments south of Gloucester despite the new employment
opportunities planned for that area.
Investment should be considered in a new local rail station at
Quedgeley. A station at this location,
with adequate parking facilities, could also meet Gloucester’s needs for access
to long distance rail services replacing the proposed Gloucestershire Parkway
station (see para 21).
19. At Gloucester,
access from Area of Search H to the A40 and M5 would be almost directly onto
the A40..
However, access to the city centre, railway station and bus station is
restricted to a single carriageway which is already congested at peak
times. There is only limited potential
for bus priority schemes and this same route would also have to handle the
traffic from an additional 450 dwellings about to be built at St Oswald’s
Park. Demand management measures would
seem to be essential.
20. At Cheltenham,
access from Area of Search I both to Cheltenham centre and to the M5 and A38 appears to be is adequate,
subject to achievable improvements to the A4019, and, if necessary, the addition
of southbound access to the M5 at junction 10 if necessary, and demand management, although links to the A435 to the
north would be more problematic (but again
demand management and design to minimise road traffic growth would be required). Access from the Leckhampton – Shurdington
area (where the major non-greenbelt urban extension has been suggested) must
either be via the Shurdington Road (A46) or via Church Road/Leckhampton Lane. Both roads are already heavily congested,
especially at peak times, with little practical prospect of significant
enhancement or alternative routing.
21. The Gloucestershire Parkway Station proposal is not sustainable. The location is not within reasonable walking and cycling distance from any centre of population. Planned bus services would only benefit from priority on the outer roads around Barnwood, and would still have to contend with city centre congestion. This would result in increased vehicle journeys to and from the station. A particular concern is that an effect of the Parkway station would be a probable downgrading of train services to both Gloucester and Cheltenham. One of the reasons the Parkway station has been proposed is lack of parking spaces at both Gloucester and Cheltenham stations, with the problem at Cheltenham most acute. A better solution would be investment at Cheltenham station and more trains calling at Gloucester, supplemented, in the longer term by a new station at Quedgeley (see para 18).
Question g - Travel
22. The spatial form of development proposed with the emphasis on urban regeneration and then on compact urban extensions together with the aim of aligning job creation and new housing more closely should help to reduce the need for travel. This presupposes, however, that the new housing and local environments will be of the highest quality so that people choose to live in the main urban areas rather than in surrounding towns and villages which are currently perceived by many as providing a better life style. See also comments on the need for restraint on new market housing in villages (para 15).
23. The urban focus, coupled with higher density
development, should enable bus services to be provided more viably. To maximise bus use, however, services will
need to be sensibly priced.
24. A concern is impact of the proposals on
congestion. The pace and scale of the
development proposed at Gloucester and Cheltenham should not be pursued unless
there is certainty that the necessary improvements to transport infrastructure
and public transport, coupled with demand management, will be delivered.
Question h - Green Belt
25. As part of the JSA exercise, the officer working group undertook a strategic reassessment of the Green Belt, examining how the current Green Belt performed against the five purposes of Green Belts. Should it prove necessary to consider urban extensions to meet longer term development needs, the exercise identified land to the north of Gloucester and to the north west of Cheltenham which could be removed from the Green Belt without effecting the essential separation of the two urban areas or impacting on high quality landscapes. These locations would appear to perform well on sustainability considerations, assuming, in the case of Area of Search H, that concerns about impacts on the flood plain can be fully addressed. CPRE therefore endorses the conclusions on the existing Green Belt but with the important proviso that all brownfield development opportunities in and around the two built up areas should be exhausted before any Green Belt incursions are considered.
26. An imperative is to prevent the further southwards sprawl of Gloucester and major development to the north of Bishops Cleeve both of which would lead to more unsustainable travel patterns and more longer journeys to work. South of Gloucester there is also an issue of local traffic making use of the M5 for travel within the Gloucester and Cheltenham area increasing congestion on what is a strategic motorway route for long distance travel. CPRE therefore endorses the proposals for Green Belt extensions in these areas.
Question i Green Infrastructure
27. The generic guidance on Green Infrastructure in paras 6.2.16 to 6.2.19 of the RSS and Policy GI1 is probably sufficient but needs to be interpreted to reflect local circumstances. There are no specific proposals on Green Infrastructure in the section on the Gloucester and Cheltenham HMA. The local authorities should be required to work jointly to agree a package of proposals for inclusion in their LDFs.
28. There is a particular need and opportunity to secure greater public benefits from a more positive approach to the management of the Gloucester and Cheltenham Green Belt (existing and proposed). In a statement issued in November 2005, we said:
“Local Development Plans should include policies to encourage the
positive management of land within the Gloucester/Cheltenham Green Belt in
order to secure a range of public benefits for the countryside which also
directly benefit residents in Gloucester and Cheltenham.
The policies should include policies for:
1. landscape
enhancement;
2. the conservation and
enhancement of biodiversity, including
new habitat creation;
3. the development of
improved informal recreation opportunities
and walking routes;
4. the targeting of
Environmental Stewardship promotion to
help achieve 1, 2 and 3;
5. the creation of
extensive areas of new woodland, where appropriate
to the landscape;
6. the long term
restoration of land which has been used for
the working of minerals or for waste disposal;
7. the support of small
producers and the production and marketing
of local products, especially local foods.”
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