14 Mar 2010

Core Strategy Consultation: act before 22nd to protect Ruscombe Valley

I've blogged on this issue many times - see background, map of some sites and links here - nearly a 100 people came to a meeting in Whiteshill regarding the threat to the Ruscombe Valley and other local sites - this is a big local issue with lots of understandably strong feelings.

This blog is about some of the issues I will be raising in my responses to the Green party re our views on the consultation re the 'Alternative Strategies' - plus some of the comments made Ruscombe Valley Action Group members and the Parish Council. It covers some general points and some more specific responses. I have tried to set out both sides of some of the key arguments to help residents make their own responses but also make clear my own views at this point. I hope this will be helpful to others - it would be great if many folk made their own responses as well - please use your own words. I have to apologise for some of the rambles and notes but I have had to hurry to get this blog completed - hopefully it still gives a good flavour of some of the key issues.

The Strategic Housing Land Availability section is where you can find details about the sites assessed for housing: www.stroud.gov.uk/docs/localplan/housing_land.asp

Download the document or complete the online from here.

Core Strategy Consultation

AONB Considerations

Many are of the view that housing developments in the Cotswolds AONB should be rejected. There is a strong case for this - see below - there is also an argument that well built quality housing in certain locations in AONB can enhance an area. It is worth noting that half Stroud District is in AONB so by excluding it, the pressure on the remaining areas is greater. My own view is that very limited AONB developments maybe appropriate but need very careful consideration.

I am for example totally against the Ruscombe Valley development - as noted many times before - this is an area of very distinctive green valley between Whiteshill and Ruscombe - one resident described it as an 'unassuming jewel'. It is hard not to appear as a NIMBY in these discussions and not knowing all the hundreds of proposed sites in detail makes it very difficult to judge one against another.

Here is the view of Whiteshill and Ruscombe Parish Council:

We are aware that many of your development options comprise of major new housing within the Cotswolds AONB, especially in the Whiteshill, Ruscombe, Randwick and Painswick areas. You will no doubt be aware that the Cotswolds AONB is a nationally designated landscape area which is afforded the highest level of protection by both national and local planning policy. Any strategic development advanced within these areas within the Core Strategy is therefore contrary to planning policy especially that contained in PPS7, which relates to Sustainable Development in Rural Areas.

The emerging RSS for the South West also recognises that the conservation and enhancement of the natural beauty, wildlife and cultural heritage of the 14 designated AONBs within the region will be given priority over other considerations in the determination of development proposals. This designation therefore excludes the allocation of new housing within the Cotswolds AONB especially if alternative options are available.
It is considered that any housing proposals in the AONB would destroy in perpetuity some of the most scenic and beautiful landscape in the country and cause great harm to the character of the remaining landscape character.

We are aware of a recent appeal decision on land at Glenfall Way, Cheltenham (ref: APP/B1605/A/08/2067428). In this appeal the developer proposed the construction of 44 dwellings on the edge of Cheltenham on land designated as AONB. Whilst Cheltenham could not demonstrate a 5 year housing land supply, the Inspector considered that exceptional circumstances were required in order to demonstrate that the development of AONB land would be acceptable.
In this case the Inspector accepted that 44 dwellings did not constitute major development. However, he did recognise that: "...the designation is an important constraint to which great weight should be given in considering options." (para 17). Whilst he accepted that the appeal site was on the urban fringe of Cheltenham he commented that this did not devalue the landscape character and that in his judgement development of the site would cause significant harm to the landscape quality and character of the AONB.

In refusing the appeal he concluded that: "Nevertheless development plan policy also affords the highest level of protection to designated landscapes including AONBs. I have no doubt that the current proposal would result in significant harm to the AONB through the change in character and appearance that would be an inevitable consequence of residential development of the site, however carefully designed and landscaped."
And "I conclude that the shortfall in housing land supply and the community benefits that would be provided in association with the scheme are of insufficient weight to over come the significant harm to the character and appearance of the AONB which would flow from development." (para 58)

There are currently no proposals in Stroud District to review the AONB boundaries and therefore any allocations proposed for these areas would conflict with development plan policies and cause significant harm to the AONB. The current spatial strategy for the area indicates that the concentration for growth in Stroud District should be in the south Gloucester area. There is therefore no planning justification for development options in the AONB.
With this in mind, this Parish Council rejects any option which advances housing developments in the Cotswolds AONB.

Issues re sustainability

The feedback form gives the impression that sustainability is at the heart of decisions - however while I welcome the questions they are to some extent meaningless - how can we realistically measure the impact of each of these proposals - the computer programmes that do that are very complex and take into account a huge number of variables from transport links to local facilities. I regret that the Council did not put the resources in to see which options would produce the most sustainable outcomes.

Another failing is the lack of planning re demography....what do our towns and villages really need - more one and two bed homes so older people can stay in our villages, more co-housing projects etc etc. This is a topic I am sure I will return to....

5 Year Housing Land Supply

Clearly we need a Core Strategy for the area - a planned approach to new residential and employment development.

Here is Whiteshill and Ruscombe Parish view: The Parish Council does...consider that there is some urgency in designing and allocating plausible and deliverable development options for the District as it is apparent that District Council cannot currently demonstrate a deliverable 5 year housing land supply. In the absence of a 5 year housing land supply, paragraph 71 of PPS3 recommends that planning applications for housing, having regard to other criteria within the PPS, should be considered favourably.

Regrettably this leads to a developer led approach to housing development and also illustrates why the Council was unsuccessful in defending Fox's Field (land north of Ebley Road, Stroud) against residential development (Appeal ref: APP/C1625/A/09/2109409).
In the selection of an appropriate residential development option it is therefore strongly recommended that such an option accords with both national and development plan policy and can be demonstrated as being deliverable in terms of social and physical constraints as well as land ownership considerations. This is considered to be the most expedient approach that will secure a robust Core Strategy for the future. These considerations are given great weight by this Parish Council when considering the options put forward by the local planning authority.

Which option?

The Whiteshill and Ruscombe Parish Council view is for a 2000 home settlement - one of their discussions was about the possibilities of Sharpness and developing an eco-town there. I have some support for this view but would welcome looking in more detail - Sharpness is not well served in many ways (otherthan canal and river) but this could lead to improvements there? But what about flooding? When I asked why it was not an option at a recent planning meeting I was told that developers did not put forward this as a proposal. I am still looking into this as Sharpness is not an option in these papers for 2,000 homes.

I wholly agree that a larger settlement will bring with it huge advantages over dispersal of 2,000 homes - the planning gain can be significant - for example you can get allotment sites, community buildings, schools, improved public transport, employment sites etc etc - whereas on 50 homes or smaller sites you basically just get a bit of affordable housing and not enough money usually for much else.

The other issue is the employment - according to the strategy we need 2 jobs for every new household as people commute out of the area for work at the moment. To me these two jobs are unrealistic but we need to aim for them and a 2,000 settlement has more chance of delivering employment sites. Indeed 2 jobs significantly exceeds the requirement of exemplary development set out in the requirements for a new Eco-town and is considered to be an unrealistic aspiration.

David Drew MP is an advocate of the dispersal to villages - he considers this is important to sustain village life - to keep post offices and shops going etc. I have discussed this before on this blog and wont go into all the details again - I do have some sympathy for this view but it depends on the villages - our local villages here, for example, are too near urban centres to gain from that - 50 more homes in the Ruscombe valley wont give us a post office or more buses. Some villages could possibly benefit but we will loose out on the planning gain from the larger settlement.

I therefore have concluded at this point that the large bulk of housing should go towards a larger settlement with some housing for dispersal - ie options A/B with some of D and G. Here are some notes accumulated from various sources which is the basis of my current thinking. Do please email me and leave comments - this is a hugely complex area and despite reading vast amounts of papers on this I am still learning about the various options and their implications.

Option A

The concentration of 2000 dwellings in one location has merit and provides a mass of development that could deliver significant community and infrastructure benefits - but I don't reckon you'll get all those houses on those sites. I would have to retain reservations on the location of such a large option to ensure that it did not infringe or cause harm to any important landscape, settlements or character areas within the District.

One view re the Governments initiative for Eco-Towns set out in PPS1: Eco- Towns, July 2009 comes up next looking at the Sharpness argument - I copy some of this in detail as it is not part of the discussion and I would wish to learn more - however having said that I have reservations about this approach - see here - having said that some of those reservations can be overcome...

We believe that the objectives of this PPS are an admirable way of achieving sustainable housing growth where the right location can be identified. Paragraph ET4 of this PPS states: "Eco-Towns are one of a range of options local planning authorities should consider when determining how to meet their current or emerging housing requirements set out in the RSS. Eco-towns should be allocated as a strategic development option within the Core Strategy, but may also be considered as part of an Area Action Plan or Allocations DPD (Development Plan Documents) where the Core Strategy has already been adopted."

The Core Strategy should look at an Eco-Town as a strategic option to accommodate the RSS housing requirement in Stroud District and to allow for future growth post 2026. The proposed Eco-Town should be designed to be a sustainable community that is resilient to and appropriate for the climate change now accepted as inevitable. It should be planned to minimise future vulnerability in changing climate, and with both mitigation and adaptation in mind. The proposed homes in the Eco-Town should be in accordance with paragraph ET9 of PPS1. In summary they should be:
1. Built to Code Level 4 and above; 2. Meet life time homes standards; 3. Have real time energy monitoring systems; 4. Have real time public transport information; 5. Access to high speed broadband; 6. Provide for an element of affordable housing; 7. Demonstrate high levels of efficiency in the fabric of the building; and 8. Achieve carbon reductions of at least 70% relative to the current Building Regulations. The proposal should also be a genuinely mixed community with approximately one employment opportunity per new dwelling. Transport options should prioritise public transport as well as walking and cycling and other sustainable means of travel.

An Eco-Town or a development option which concentrates all the proposed housing into one location cannot be accommodated in the north of the District as this would have a detrimental impact on the character, identity and setting of most of the towns and villages. It is also considered that the services and infrastructure in this area do not have the capacity to accommodate further substantial growth. Equally the east of the District is heavily constrained by the Cotswolds AONB which national planning policy identifies as being inappropriate for major new development options.

This option could ensure that further sympathetic growth could be added to this development in the future to ensure that Stroud District has an identified and appropriate growth centre where subsequent growth, post 2026 can be focused and planned accordingly. Although I do have to wonder and question the whole approach to development - it is just not possible to keep on growing - buy hey I've made that point about growth many times before.....

Taking all this into account they go onto suggest an Eco-Town centred on Sharpness - arguing there is a lot of brown field land, a possibility of rail connection, employment opportunities and room for further growth.

Development at Cam, Eastington or west of Stonehouse?

Larger sites offer advantages as noted. Development at Eastington and West of Stonehouse, however would increase congestion on the main artery link to the M5 and erode the valuable open space which currently separates our District from Gloucester. Clearly new motorway links could be part of any development along with the reopening of the rail line. However it is by no means a good choice. Cam is also not ideal. Indeed there are few 'good' choices in the whole strategy - it is more about seeing where they will do the least damage with the most benefits....

Option B

Option B comprises mainly of the segregation of the 2000 homes requirement into two different locations. The proposed locations for growth in these options are Cam, Eastington, Stonehouse, Brimscombe and Thrupp or Whitminster. Essentially this option now includes Whitminster and Brimscombe and Thrupp. As noted one or two of the first three sites could be suitable but I would rather see an amount of the houses go to dispersal.

This option spreads the amount of development to two separate locations and thereby depriving the District of the opportunity to get any planned community benefits, concentrated growth or regeneration. Whitminster has relatively few landscape constraints - the concentration of growth in this village would further decrease the open land between Stroud and Gloucester. This location is therefore considered not very appropriate.

Brimscombe and Thrupp are essentially linear settlements in the valley of the A419. Given the physical constraints which exist here it is inconceivable how a planned and logical development that would serve the future needs of the District could be achieved here. Stroud Town Council have also ruled out this possibility.

Option C

Option C is tantamount to the dispersal of development in an unsustainable manner. This option has identified 8 settlement options. However, on closer examination it is apparent that these 'settlement options' are small unsustainable villages where the addition of 250 dwellings would destroy the character of the settlements and would create inappropriate and fragmented development across the District. The addition of 250 dwellings to each of these settlements would not create a significant mass of development sufficient to provide physical and social infrastructure improvements and would therefore create unsustainable patterns of development contrary to the objectives of PPS1.

This option also advances 'major' development within the Cotswolds AONB which directly conflicts with national planning policy advice on rural areas contained in PPS7 (2004) - see discussion above. Paragraph 21 of PPS7 recognises the AONB as a nationally designated area where the highest status of protection is provided to the landscape. This protection rules out the development of significant areas of new housing that would erode the quality and character of the landscape. Paragraph 22 of PPS7 specifically states that major development should not take place in these designated areas, except in exceptional circumstances. Given that other options exist to accommodate the new housing for the District, it is considered that exceptional circumstances do not exist for the development of new housing within the Cotswolds AONB.

Option D

Option D provides an opportunity to seek out appropriate brown field sites within the Stroud Valleys for development. However it is questionable whether this is deliverable on the sites noted - 1400 dwellings is alot. Certainly there is room for some of the dispersal at these sites.

Options E, F and G

Options E, F and G are dismissed as being inappropriate and unsustainable as the sole way forward. As one commentator put it: "These options are tantamount to "spreading the pain" without regard to the concepts of sustainability or without regard to the sensitive environment in which Stroud District is located." I am not sure this is entirely true as I consider there are possibilities at some of these sites for dispersal - and taking into account the dispersal arguments above there could be some benefits.

Good luck with your responses to this consultation!!

1 comment:

Philip Booth said...

Response from SDC re Sharpness for those who are interested:

In respect of Sharpness, a number of sites were assessed against Government guidance. The SHLAA was a key tool and the methodology was the subject of a workshop to agree the way of assessing sites, determining potential and assessing housing yield. Each site was assessed on deliverability and developability (available, suitable and achievable). A number were excluded from the assessment on the basis that full planning permission was granted or that it was a Key Employment Site recommended for retention in the Employment Land Review. The remaining sites were looked at as part of the assessment. All sites were considered by a panel of 11 people who are experts in the development industry. They concluded that five sites were not achievable. This left one site of potentially 113 dwellings at Sharpness.

The Core Strategy alternatives considered this potential. In the Cluster Strategy the Berkeley cluster includes Newtown/Sharpness. Options E (Town and Country Combination Strategy), F (Rural Communities Strategy) and G (Dispersal Strategy) all considered Sharpness as a potential component in delivery as part of Hinton Parish. These alternatives were based on the information we had at that time. It was unlikely it could deliver one of the more concentrated strategies.

Furthermore the background papers looked at settlement classification and accessibility to services. Newtown/Sharpness is a limited settlement with limited facilities (third tier) which could be a key weakness. This with initial SHLAA findings led us to believe that it was unlikely to be able to accommodate a strategically large concentrated development. Neither did pre-consultation with District Councillors raise this area as having potential for a concentration type strategy.

However it must be said that this assessment process cannot preclude other landowners or developers promoting another option to meet the alternative strategies for consideration. If this happens, further detailed analysis would be required on any such sites to meet a strategy in terms of availability, deliverability and achievability. Other planning policy constraints would also have to be taken into account such as flooding and the Severn Estuary as an internationally designated area for biodiversity for example.