CPRE GLOUCESTERSHIRE BRANCH

Comments by CPRE South West on Proposed Changes by the Secretary of State to Draft RSS - Section 4(2) HMAs

Section 4 Sub Regional policies and housing distribution (2- response to HMA policies)

Policy/paragraph reference

Policy HMA3: Gloucester and Cheltenham and supporting text

• See our overall comments at the beginning of Section 4 on the use of unjustifiably high housing projections, unrealistically high economic and job growth assumptions and lack of consideration of local conditions including deliverability of infrastructure that has resulted in excessive HMA housing allocations.
• See our overall comments at the beginning of Section 4 and under Policy HD1 (and its associated housing tables) on the need to remove wording that implies that the housing allocations should be regarded as a minimum.
• See our overall comments on the lack of consideration of the adverse impact on the environment and service provision of the higher levels of development proposed for rural areas, which is particularly out of kilter with realistic projections of job growth.
• See our overall comments on the need for improved policy to ensure a coordinated and orderly progression to development.

C. Summary

• We strongly support a focus of development at Gloucester and Cheltenham.
• We welcome the intention to maintain the overall integrity of the green belt and maintain the separate identities of Gloucester and Cheltenham.
• A far more cautious approach to development is required based firmly on Plan, Monitor and Manage. We do not support the higher housing numbers proposed by the Secretary of State and recommend a return to the levels of development proposed in the draft RSS.
• The wording at least should be removed from the housing growth numbers.
• The job figures should be revised to more realistic projections and removed from the policy itself. Employment land provision should similarly be removed from the policy and adjusted to a more realistic level. The wording about is welcome.
• The proposed urban extensions should only be brought forward after all opportunities for redevelopment of previously developed land have been exhausted, and then extensions should be brought forward sequentially.
• We have particular concerns about a number of the proposed urban extensions, in addition to our points about phasing and a sequential approach. In particular, at the Gloucester SSCT we oppose development within area of search 3B and are concerned about possible flood risk within area of search 3D. At the Cheltenham SSCT we are concerned about the impact of development within area of search 3E, and phasing and possible flood risk within area of search 3F. The policy and key diagram should be modified accordingly.
• At the Gloucester SSCT we see no need for further urban extensions in the early years of the strategy. There is a risk of undermining the regeneration being led by the Gloucester Heritage Urban Regeneration Company. LDFs should require phasing of already agreed urban extensions and a sequential bringing forward of any further extensions. The challenge of making full use of underused and derelict land in Gloucester should be reflected in para 4.1.26.
• In considering growth in movement in the corridors identified in para 4.1.29 an aim should be to minimise journeys by car.
• The removal of any reference to the Gloucestershire Parkway Station proposal is supported.
• Strategic green infrastructure policy for the SSCTs should be developed as part of the proposed partial review of RSS.

D1 Reason

We agree that a focus of development at Gloucester and Cheltenham will provide homes closest to where most jobs are likely to arise, encourage public transport use and support regeneration. Any policy of greater dispersal of development would add to traffic movements and congestion as well as creating excessive new market housing in villages and the market towns.

We accept that the most sustainable location for any new development that cannot be met within the existing urban areas is well designed and compact urban extensions. However, in this period of economic uncertainty a far more measured and cautious approach to development is needed based firmly on “Plan, Monitor and Manage.”

We do not support the higher housing numbers proposed by the Secretary of State, either for the SSCTs or for the remainder of the HMA where the proposed uplift in provision has not been justified and would undermine the focus of the Strategy.

The proposed urban extensions should only be brought forward after all major opportunities for redevelopment of previously developed land have been exhausted, and then extensions should be brought forward sequentially. The RSS should require urban extensions at Gloucester and Cheltenham to be brought forward sequentially: the order of bringing forward should be addressed in the LDF Core Strategy where we note the intention of Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to work jointly, with the assistance of Gloucestershire County Council on infrastructure matters.

We had supported the Regional Assembly’s proposals for extensions to the Gloucester and Cheltenham Green Belt south of Gloucester and north of Bishops Cleeve and remain of the view that such extensions would be justified. We note that the issue of green belt extensions is to be considered in the proposed partial review of the RSS (Para 4.1.93).

Gloucester SSCT

At Gloucester SSCT major development is underway at Kingsway (Quedgeley) and has planning approval at Longford and Hunts Grove. We see no need for further urban extensions in the early years of the strategy beyond those currently being developed given the extent of redevelopment opportunities within the Gloucester urban area.

In a period of economic uncertainty, to secure effective regeneration of the city centre and docks area and to fully exploit other regeneration opportunities, it will be vital to carefully phase release of land for the already agreed urban extensions to avoid undermining the regeneration being led by the Gloucester Heritage Urban Regeneration Company. The proposed further urban extensions should be deferred until regeneration work has been largely completed and should then be brought forward sequentially. The order of bringing forward the extensions should be determined as part of LDF joint Core Strategy.

We oppose any development within area of search 3B because of its impact on the Cotswolds AONB and on Robinswood Hill. Development at this location was rejected by the Joint Study Area team because of its impact on the setting of the Cotswolds AONB and Robinswood Hill (the land is defined as SLA in the County Structure Plan Second Alteration) and an extension to the green belt had been proposed for the area in the draft RSS to curtail the further southwards sprawl of Gloucester and safeguard it from development in the longer term. Development at this location would also be inconsistent with RSS Policy ENV3 which requires that particular care be taken to ensure that no development is permitted outside AONBs which would damage their natural beauty, character and special qualities or otherwise prejudice achievement of AONB purposes.

Given its location in an area where flood risk is a significant issue, the scale and form of any development within area of search 3D must be informed by the Environment Agency Regional Flood Risk Assessment and by more detailed local flood risk assessments.

Cheltenham SSCT

Development within area of search 3E has implications for the setting of the Cotswolds AONB and would be inconsistent with RSS Policy ENV3 which requires that particular care be taken to ensure that no development is permitted outside AONBs which would damage their natural beauty, character and special qualities or otherwise prejudice achievement of AONB purposes. The EiP Panel was concerned about harm to the AONB and the outlook from Leckhampton Hill and concluded that the area of search did not imply that all of the land should be developed for housing. Given the sensitivity relating to development at this location, the final version of the RSS should make that clear too. Joint working between Cheltenham and Tewkesbury Boroughs will be necessary to determine the most appropriate form of any development at this sensitive location. The key diagram should denote the boundary of the AONB and the area of search drawn to make it clear that the AONB will not be affected.

Development within area of Search 3F, the proposed major north-west extension to Cheltenham, should be deferred and then carefully phased to avoid undermining regeneration of previously developed land within the Cheltenham urban area. It will also be important to retain the separate identities of Elmstone Hardwick and Uckington. There may also be a flood risk issue at this location and the final form of any development must be informed by the Environment Agency Regional Flood Risk Assessment and more detailed local flood risk assessments.

Transport issues

The scale and location of growth will inevitably lead to greater movement in the corridors identified. As well as avoiding local journeys taking place on the M5, paragraph 4.1.29 should indicate an aim to minimise journeys by car through enhanced quality in public transport provision and provision for cycling, coupled with demand management measures.

The proposal for a Gloucestershire Parkway Station was not supported by CPRE because of concerns about location, traffic generation and implications for services to both Gloucester and Cheltenham stations. We therefore support the removal from the RSS of any reference to this proposal.

D2 Revised wording suggested

See Summary plus:

• Para 4.1.26 Add to the second sentence ….“and to make full use of underused and derelict land.”
• Add new paragraph after paragraph 4.1.28 requiring that LDFs provide for the sequential bringing forward of urban extensions after all major opportunities have been exhausted for redeveloping previously developed land.
• Para 4.1.29 Add additional sentence. “An aim should be to minimise journeys by car through enhanced quality in public transport provision and provision for cycling, coupled with demand management measures.”
• Add new paragraph after 4.1.31 to reflect the need for phasing of already agreed urban extensions for Gloucester and a sequential approach to further extensions.

October 2008