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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options

Responses

List of answers to the specified question
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#714423

5 CONCLUSIONS

5.1 Assessment against the tests of soundness

5.1.1 Having considered the JCSR, Gladman are concerned by a range of matters including the proposed strategic allocation at Ashchurch.

5.1.2 The Plan must be positively prepared, effective, justified and consistent with national policy, and the overarching strategic policies relevant to the plan area to be found sound at examination.

5.1.3 Through this representation, Gladman have identified significant concerns regarding the proposed allocation at Ashchurch. Based upon the Council’s own evidence, we consider that the proposal would have an unacceptable impact on the existing highways and have serious concerns regarding the ability of the scheme to provide the infrastructure required to support a scheme of the proposed size. We therefore consider it necessary for the Council’s to identify other strategic options at the earliest possible opportunity.

5.1.4 Gladman have land interest to the south of Tewkesbury. We consider that the land has the ability to deliver a high-quality, sustainable and attractive new village, that could accommodate up to 3,00 new dwellings, land for employment, a local centre, community facilities, schools and associated green infrastructure network. We would welcome the opportunity to meet with Tewkesbury Borough Council to discuss our proposals in more detail and consider ways in which our proposals could assist the Council’s to meet the local housing needs identified through the review process.

5.1.5 Gladman welcome the opportunity to comment on the GCT JCSR Issues & Options consultation and hope that the Council find these submissions constructive. Gladman request to be added to the consultation database and look forward to reviewing future versions of the JCSR in due course.

 

01 Apr 2019 15:57
#714414

Conclusion

Bruton Knowles supports the identification of part of our client’s land as an option for growth and we consider that further land could be allocated for 3,000 units for acres the reasons set out above.

 

01 Apr 2019 15:39
#713410

Further to the Ashchurch Concept Masterplan (ACM) the following is the response from Ashchurch Rural Parish Council (ARPC) which is additional to the collective response from ourselves and neighbouring various parish councils. It reflects the opinions of our residents and the community Ashchurch Parish at large.

We believe that this ACM is fundamentally flawed & undeliverable as previously advised and the fact that we are being asked to comment within this framework is not necessarily productive. However we can advise as follows:

Consultation
• This ACM was devised and created with no input from the local community and ARPC. Tewkesbury Borough Council Statement of Community Involvement (SCI) is dated May 2013 and sets out how the Borough intends to engage with communities during the planning process which includes preparing development plan documents such this ACM.
• We note that there is a section in the SCI which covers Plan & Policy preparation and that paragraph 2.1 of this SCI states:
“Preparation of a local plan is governed by statutory procedures. The council will ensure that whilst complying with the regulations we will endeavour to go beyond these to create an inclusive, far reaching and engaging approach to plan preparation”.
In addition, the NPPF clearly states at paragraph 16c that:
“Plans should be:
c) shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees:”
• We note that TBC are expected to consult with and work with local communities, as set out in NPPF para. 40:
Local planning authorities have a key role to play in encouraging other parties to take maximum advantage of the pre-application stage. They cannot require that a developer engages with them before submitting a planning application, but they should encourage take-up of any pre-application services they offer. They should also, where they think this would be beneficial, encourage any applicants who are not already required to do so by law to engage with the local community and, where relevant, with statutory and non-statutory consultees, before submitting their applications.
• The ACM seems to be a strategy that has been predetermined without any consultation and without consideration of possible alternative provision. Therefore, it cannot be concluded that a Garden Town in Ashchurch is the most sustainable approach to meeting Tewkesbury’s housing need.
• The ACM plan seems to pre-judge any consultation with the community and is being presented as a fait accompli rather than a properly considered approach. It is seemingly being presented as a magic bullet to solve all the issues that TBC face rather than a cohesive plan with alternative strategies to resolve the existing housing shortfall that has been created.
• Overall the ACM and the subsequent last minute addition of 2000 dwellings for a Garden Town status is a significant departure from and contrary to the agreed JCS development plan where it states under:
• item 2.23 that “The character of the rural area will be protected and enhanced”. Item 2.25 states “In addition to any special provision through a Green Infrastructure Strategy, distinctive landscape character will have been protected, landscape features maintained and enhanced, and the countryside will be richer in wildlife with improved access for all. The tranquillity of the countryside will have been safeguarded, and noise and light pollution minimised. New development will be appropriate in scale, design and energy efficiency that specifically state that the character of the rural area will be protected and that the tranquillity of the countryside will be safeguarded and noise and light pollution minimised”.
• In addition item 3.2.4 of the JCS states “Most of this development will be in the form of urban extensions within Tewkesbury Borough, because of the nature of the administrative boundaries in the JCS area. Tewkesbury town plays a smaller role in accommodating new development due to its size, and the rural areas will accommodate a lower amount of new development, most of which already has planning permission”.

The ACM clearly totally ignores the above approved position.

The Plan
• The scale of the plan is to build 8010 dwellings plus a further circa 2000 dwellings seemingly added at the last minute to comply with Garden Town status that requires a minimum of 10,000 dwellings. This effectively more than doubles the population size of Tewkesbury and the surrounding area over the next 15 to 20 years into what is currently a distinctly rural community. It effectively tries to satisfy the future demands of the whole of the Borough of Tewkesbury and perhaps demands from other areas into one location in the guise of a Garden Town.
• Plans to develop a further 120 Ha of employment in and around junction 9 of the M5 is ill considered and undeliverable. There is no detailed amount of employment growth at Ashchurch set out in existing policy and strategy within the JCS and thus no justification for this volume of additional employment development.
• In addition, the plan to develop land at Fiddington for employment use is contrary to the evidence base submitted by TBC for the JCS when it considered the site for residential use. The JCS inspector accepted that this site was suitable for residential development and envisaged that the site could contribute to TBC’s 5-year housing land supply and recommended that the land at Fiddington be allocated for dwelling development. Why are TBC ignoring this?
• We question the sustainability of a New Town at Ashchurch alongside the existing town of Tewkesbury. If the ACM became reality this New Town combined with the already approved Retail Park nearby will either likely become a serious competitor to the economic well being of Tewkesbury Town or itself be unsustainable. There is no evidence within the ACM to suggest that both could flourish economically.
• It is well documented that the infrastructure is simply not in place to accommodate the proposed level of growth. Proposed development of additional roads to alleviate the congestion already in place on the A46 are not practical and even if achieved, will not deliver the relief required to accommodate this level of growth.
• Construction of circa 10,000 houses and an additional 120 Ha of employment land will generate so much traffic locally that substantial remodelling of the existing road network involving major construction and demolition of existing structures including some housing will be necessary to achieve it. Even then, significant congestion will ensue for all local residents as the plan tries to “shoe horn” these additional traffic volumes into the local road network. Additionally, we question whether the funding is available and if such a scheme would be given priority. We are also unclear about the phasing of the new required infrastructure.
• Major additional infrastructure will also be necessary in the form of an expressway from Teddington Hands to junction 10 M5 to divert through traffic away from junction 9. Once again no answer to where this is possible funding will come from?
• The southern relief road within the plan is simply a device to open up existing farmland for development. This road will join the existing by pass and bring traffic from Teddington Hands area. It is not clear what happens to this traffic when it arrives at the existing Tewkesbury by pass except to cause further congestion. Where is this traffic trying to get to? It is clear that this attempt at “blue sky thinking” is flawed with little consideration as to what the effects would be.
• The ACM plan sets out on page 42 under the heading Transforming the Sustainable Movement Environment a number of initiatives and interventions such as park and ride, rail improvements, bus service improvements and active travel and yet there is no viability assessment. It is seemingly added without any substantive thought even at this conceptual stage. For example where are these people using park & ride going to and why?
• Phase one is undeliverable as stated within the plan. The proposed bridge over the railway north of the existing level crossing and subsequent new road to effectively connect the B4079 and B4080 achieves very little in terms of traffic relief. It is seemingly a road to nowhere. Once again this is simply another device to open up development land north of the MOD site for housing without consideration as to where the residents will want to travel to and the required infrastructure to support this. We question whether incoming residents would want to use this new road.
• Phase two is reliant on the release of the MOD site which will not even be considered for release for another 10 years and even then, will not necessarily be available for some years after that. The end period for the JCS is 2031, and it is questionable whether this site will become available within the plan period. We therefore question why this site is even under consideration. It is our view that the MOD site should be considered a long term potential site able to provide additional capacity for development when availability confirmed. It certainly should not be considered until there is a full review of the JCS. We also note that Phase one is reliant on the release of this MOD site to provide access to the A46 and a possible solution for the Phase one residents, but even then, the additional traffic will generate more congestion onto a road that is already at capacity. These points on the inadequacy of the infrastructure proposals were made in preceding comments.
• The proposal pays little regard to the fact that some degree of flooding is a regular occurrence in the area. There are 2 water courses – the Tirle and Carrant Brooks both of which feed into the rivers Avon and Severn. Surface water is effectively held on the fields prior to feeding into various ditches criss-crossing the area and into these brooks. Major construction of housing and the infrastructure to support them will remove flood storage capacity for this surface water. This will exacerbate flooding risks for existing residents whose homes are not built on elevated foundations but also those properties down stream. Localised simplistic theoretical solutions such as attenuating and balancing ponds will not compensate for the loss of these flood storage features and yet once again planners are seemingly ignoring these risks
• The idea of creating a new town centred around the church of St Nicholas at Ashchurch just because there happens to be a train station close by is once again flawed. The area around the church is occupied by a Grade 2 listed building, ancient trees and grounds including a graveyard with some land gifted in trust for the benefit (not ownership) of the Rector. To seemingly trample over these features is not acceptable or necessary. It may be possible to create a “centre” further to the east but even then, the possibility is limited unless major demolition of existing housing is undertaken which is perverse given the housing shortage.
• The train station itself has limited car parking for its current use let alone any expansion. Theoretical belief that residents within a rural area who could utilise the train more will use public transport to access the station is again flawed.

To be constructive we recognise that some development is necessary within the Borough and certainly the parish of Ashchurch has capacity to satisfy some future housing needs. We note the progress at our neighbouring parish of Stoke Orchard. This new development should be confined to housing and be compliant with the JCS plan as identified above. The MOD site should only be considered for mixed used development when its availability is certain.

There are a number of alternative sites across the Borough that provide sufficient additional housing capacity that can be created without detrimental effects of flooding or development of major infrastructure works. These developments should be of a scale similar to Stoke Orchard with house design commensurate with a rural environment within the local area.

We refer you to the traffic evidence work that sits alongside the adopted JCS for junction 10 M5 to be made 4 way for all movements. We understand the design phase is currently underway and is necessary for the proposed development west of Cheltenham. Land to the west of this junction is an alternative site that is available for employment having a larger capacity where the transport and flooding issues either do not exist or are less pronounced. There being circa 450Ha of open countryside available and certainly enough to provide 120Ha of employment development and some housing in an area where additional major infrastructure is not required. This would appear to be an area better suited to satisfy the shortfalls in Gloucester and Cheltenham.

28 Mar 2019 13:02
#713403

CONCLUSIONS
These representations have been made by Miller Homes in relation to the Gloucester, Cheltenham and Tewksbury (GCT) Joint Core Strategy (JCS) Issues & Options consultation.

The representations specifically respond to the questions raised through the consultation process. Whilst clear not covering all the responses made, the overarching nature of the representations made are as follows:

• Support for the complete review of the JCS;
• The need for the JCS review to accommodate a sufficient plan period to ensure appropriate commitment is given to spatial planning of the area. It is recommended the end date should be 2041;
• Acknowledgement that the housing requirement within the JCS will increase above existing need figures;
• The JCS Review must be sufficiently flexible to ensure additional housing requirements from a revised standard method can be accommodated within the JCS;
• Acknowledgement that the existing commitments have failed to deliver as anticipated and therefore a commitment to new locations for urban extensions growth must be found on sites that can deliver in the short and medium term;
• That the land at Fiddington, Ashchurch, promoted by Miller Homes Ltd, provides an
opportunity to extend the boundary of the Ashchurch Draft Concept Masterplan area to allow for additional development, including much needed affordable housing, to address the likely future development needs in the JCS area.

MHL would welcome further engagement on the emerging JCS and would be happy to discuss the representations in this submission prior to publication of the next iteration of the plan.

28 Mar 2019 12:49
#711806

Ashchurch Rural Parish Council has written to a number of nearby local councils to seek their support in opposing the Ashchurch Concept Masterplan that Tewkesbury Borough Council has launched and subsequently amended by adding 2000 houses to allow for Garden Town status. Gotherington Parish Council discussed the issues arising at its meeting on Tuesday 8th January 2019, and decided to add its voice to Ashchurch Rural Parish Council in declaring that:

  • the current infrastructure is unable to sustain a development of the scale and location planned. The A46 is at capacity and the Masterplan concedes this fact stating that junction 9 of the M5 in particular is a significant problem with major works required to alleviate the issue. The major works referred to above may alleviate some traffic from passing through the area via J9 but it will not alleviate traffic from passing within nor from this area.
  • There is currently c 115 Ha of employment land in place already with planning permission for an additional 25Ha adjacent to J9 which will further exacerbate the problem. The plan proposes to add yet another 120Ha of employment land around J9 thus doubling it. The resultant additional traffic being added to what is already a serious problem and there are no realistic solutions within the plan.
  • Phase 1 of the Masterplan proposes 3180 houses within an area where there is no solution possible to develop infrastructure to access the A46 unless the MOD site is available. There are no plans to release this site with the next review due in approx. 10 years and even if released at that time will take some years to become available. It also conjoins Northway and Ashchurch developments by infill (contrary to Garden Town principles) and subsequent Phases are tenuous without any substantive deliverable solution to the traffic issues within the area.

Not only will the current Ashchurch Masterplan destroy existing rural communities it will also exacerbate the significant problems on the A46, & J9 of the M5 resulting in unacceptable congestion, and is likely to have a detrimental affect on the flow of traffic along the A435 that runs through the parish of Gotherington.

27 Mar 2019 16:57
#711779

Thank you for showing a passion in trying to develop the Tewkesbury area. Unfortunately I feel the proposed developments are excessive for our town. 10,000 houses would nearly double the population of  Tewkesbury, and this is not a development, but an expansion and creation of a large town that would  certainly have a culturally different feel to now.  

I feel the plan needs a comprehensive review, particularly with regards to the impact on flooding, road infrastructure and rural life. Whilst I appreciate there is some scope for additional development, developments to the extent that have been proposed create a genuine risk to people's lives. In 2007, the floods in Tewkesbury claimed 3 lives and destroyed hundreds of homes. In the consequent floods of January 2008, I very nearly lost my own life to appendicitis as emergency vehicles were unable to access the area I live in due to flood water. I am deeply concerned on reading the document that proposed areas to be built on include flood plains, and given the ever rising sea levels, I feel this will only exacerbate the inevitable future floods. Such as the Ashchurch army camp and other industrial brownfield sites alone will allow for adequate expansion and reduce the flood risk by taking up less floodplain.

I agree that some development should take place, but the full proposal stated is far too excessive and would effectively double the land and population that Tewkesbury currently takes up. Gap filling within the town and army camp as well as other brownfield sites would be more sustainable in the long run.

The road network and infrastructure proposals imply that these will be adapted once the developments have been carried out. Given that it can take upwards of 30mins to travel 2 miles at the moment, I think this would be a big mistake and no doubt double journey times with the increase of traffic.

Tewkesbury has so much to offer in terms of its green spaces and natural outlook, it would be such a shame to destroy the rural feel that is already becoming a rarity in this country.

Please look after this precious and unique town and be careful not to turn it into another area of industry and limitless expansion.

On a side note, Gloucestershire in general has so much to offer in terms of conservation, with Slimbridge wildlife and wetlands reserve being described by David Attenborough as the home of British conservation. Along with the Forest of Dean, the Costwolds and the many rivers of the county, Expansion in the field of conservation within the county would put us at the forefront of this very important and current topic, and with the right direction, I genuinely believe Gloucestershire could set an example to not only Britain, but the rest of the world, in how to live and work with our natural environment to protect it as well as ourselves.

27 Mar 2019 16:52
#711740

With regard to the presentation of the above "Concept Plan", which we were shown late last year, I would raise the following issues.  

The "Public Consultation" which I visited was of very little use, and totally uninformative. Having viewed the plans which were proposed up on tables in the village hall, we then discovered that those presenting the plans were basically working to a script.  

Whatever questions we put to them, we were always given the same answer, to the effect "Well, this is only a rough plan, nothing is definite, it's just a suggestion, and there might be other plans". Any attempts to elicit any worthwhile information, faced with the terrifying prospect of the plans in front of us, was met with good-natured, and polite obfuscation.

The "Public Consultation" was no such thing; one cannot have any worthwhile exchange if absolutely no information is forthcoming. I stood next to an elderly lady who realised that, according to the plan, she would be living in the Fiddington Industrial area. I could see tears of frustration and fear in her eyes as she looked at the diagram, and, asking questions, realised that the gentleman she was talking to was wilfully ignoring any plea for information.

As far as the plan is concerned, it is staggering that Tewkesbury's heritage of being a beautiful market town, surrounded by ancient and historic countryside, is to be squandered, and wrecked for ever. There are countless pictures of Tewkesbury illustrating its beautiful setting. It is the reason so many people bring their families to live round here. Now it seems, one way or another, this is to vanish forever in a greedy land grab. 

Perhaps the planners feel that the people who live around the rural area of Aschurch, Pamington, and the surrounding area, do not particularly matter. That the countryside they have invested their lives in, will be turned into an enormous housing estate and industrial area.  

Obviously we do not know whether the planners and/the council have consulted the landowners to see if they are willing to sell. As there is so much money involved, we can guess the answer. 

We are under no illusions; houses need to be built, but this is simply staggering, with little regard to the surrounding infrastructure.  

It is desperately upsetting, and many of us are questioning whether we wish to continue living here, when such a despicable action seems imminent. 

Or, of course, it might be "Just a suggestion, nobody really knows..."

27 Mar 2019 16:45
#711711

Please see attached

27 Mar 2019 16:40
#711688

Our main concerns are outlined below:

1) Necessary infrastructure planned after the majority of houses have been built.

The Concept masterplan states that the majority of houses (4665 out of a total of 8010 houses) will be built in Phases 1 and 2, before the necessary infrastructure will be in place. These developments, together with the planned increase in employment in this area, will only add to the existing severe capacity and congestion issues in the Ashchurch area. The transport upgrades planned in Phase 1, such as localised link and junction improvements, will be of limited benefit and will not cope with the huge increase in demand, never mind alleviate existing congestion issues. A more substantial and comprehensive road infrastructure improvement is required before building commences in Phase 1.

2) Flood Zones

The impact of new building developments on floodplain areas is always a key issue for Tewkesbury and Ashchurch, particularly as developers will build new homes on raised land but not protect existing homes. In addition to reserving natural floodplains to limit flooding, the storage capacity of the floodplains needs to be increased to retain the additional surface water run-off from the proposed sites. Additional land should be allocated for detention basins and/or swales to retain the additional surface water run-off from the new development sites (industrial and residential) in all Phases.

3) Impact on Existing Residents

Clearly the scale of developments on this scale will have a significantly negative effect on existing residents, completely overwhelming and transforming the local community, in addition to changing the overall appearance and life style in the Parish itself. Local residents have chosen to and invested in living in Ashchurch because of its attractive rural character and have not chosen to live in a "garden town".

27 Mar 2019 16:36
#711677

Please see attached

27 Mar 2019 16:34
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