District Council Examination of Local Plan Stage 2 Hearing Statement Matter 3C: Making Places – Cam &

1.0 Introduction

1.1 The site allocations contained within Chapter 3: Making Places of the Submission Draft Local Plan (including Proposed Changes) are considered appropriate, sustainable, deliverable, viable, fully justified and soundly based.

1.2 The allocated sites both contribute towards the delivery of the development strategy and are themselves suitable, available and achievable sites for development having regard to what constitutes sustainable development.

1.3 The principal evidence base documents supporting the site allocations in the Plan include: (i) Strategic Housing Land Availability Assessment, 2011 (CD/B4); (ii) Employment Land Study 2013 (CD/C4); (iii) Stroud Infrastructure Delivery Plan (Phase 3) 2013 (CD/C6); (iv) Strategic Flood Risk Assessment (Level 1 and 2) 2008 & 2012 (CD/D3); (v) Development location comparison and carbon footprinting study 2011 (CD/D7); (vi) Landscape Sensitivity Study 2013 (CD/D14); (vii) Strategic allocations supporting statements 2013 (CD/F3); (viii) Towards a Preferred Strategy – pros and cons of potential locations for strategic growth 2011 (CD/F15); (ix) Draft Plan Viability Study 2013 (CD/F19); (x) Flood Risk Sequential Test Assessment of Proposed Development Sites 2013 (PS/B2); (xi) CIL Viability Study Annex to Draft Plan Viability Study 2014 (PS/B6); (xii) Transport Impact Assessment 2014 (PS/B26); (xiii) SFRA Level 2 Addendum Report 2014 (PS/B28a); (xiv) Flood Risk Sequential Test: Assessment of Development Sites Update 2014 (PS/D14d) (xiv) Junction Capacity Assessment 2014 (PS/E22) (xv) Infrastructure Delivery Plan Refresh 2014 (PS/E23) (xvi) Level 2 SFRA Addendum Paper: Sharpness (PS/E24) (xvii) Flood Risk Sequential Test Update 2014 (PS/E25) (xviii) Sustainability Appraisal (various documents including CD/A4a, CD/F17, CD/F18, PS/E18); (xix) Habitat Regulation Assessment (various documents including CD/D9, PS/E19, PS/E20).

1.4 The sites are considered deliverable and the following sections also set out the latest information regarding current planning status of the sites and the work site promoters are undertaking to bring forward the sites for development.

1 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley C. CAM & DURSLEY (Policy SA3) Key issue: Is the development strategy for Cam & Dursley appropriate, effective, deliverable, sustainable, viable, fully justified and soundly based, including the proposed Site Allocation?

C.1 Is the amount and type of development proposed at the allocated site appropriate, sustainable, deliverable, viable, fully justified and soundly based, including: a. the amount and type of proposed housing development (450 dwellings); b. the amount and type of new employment development (11.4ha); c. other proposed uses and associated infrastructure and facilities. d. infrastructure-related issues, including the ability of existing facilities to accommodate the additional population, access, traffic generation (including M5;J12/J13), flood risk and wastewater, highway improvements and visual/environmental issues, including impact on the AONB and surrounding countryside?

C.1.1 The proposed allocation of the site North East Cam for 450 dwellings and 11.4 hectares of employment land has been positively prepared to meet objectively assessed needs arising from within Stroud for the Plan period identified in the NMSS Report (PS/E09), as reconfirmed in the latest Council Response to the Inspector’s Initial Views (REX/B17). The proposed allocation is justified by the evidence base, including the testing against reasonable alternatives and is deliverable as it is being actively promoted currently through the pre-application process and is expected to deliver housing through the remaining Plan period.

C.1.2 The site is fully in accordance with the development strategy as it involves a large planned mixed use urban extension to one of the District’s main settlements; it will deliver employment and housing (including over 135 affordable houses) together; and will bring forward infrastructure to support the development including a landscaped linear park, open space and community facilities together with contributions towards off-site education, bus services and improvements to Cam and Dursley railway station. It is therefore fully in accordance with the principles of concentrated development as set out in the Submission Draft Local Plan, in particular, paragraph 2.10 where reference is made to “There are five strategic growth locations: at Cam, through the Stroud Valleys, south of , at Sharpness and to the west of Stonehouse” (CD/A1).

C.1.3 The settlements of Cam and Dursley adjoin each other and make up the District’s second largest population centre (after Stroud Valleys). The Settlement Study (PS/E21) demonstrates that both Cam and Dursley are relatively sustainable settlements with particular strengths. Cam, in particular, has the second largest economically active population in the District (after Stonehouse) with a good proportion of workers living locally and has employment sectors forecast to see job growth. Residents benefit from very good accessibility to most key services and facilities and there is also a mainline railway station. Dursley has an important strategic retail and community services role within the District with residents

2 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley benefitting from very good accessibility to most key services and facilities. Table 18 of the Settlement Study demonstrates clearly that Cam and Dursley are rightly identified as first tier settlements where there are the best opportunities for future sustainable growth in the District

C.1.4 However, both settlements have challenges which the Settlement Study summarises in chapter 5. In particular, both settlements act as dormitory towns for the District’s working population. The area has suffered in the last ten years from the closure of major manufacturing facilities, in particular the Lister Petter / Lister Shearing complex located to the north of Dursley. The allocation of a large employment site within the North East Cam allocation would offer opportunities to provide more local job opportunities and help to ensure more balanced housing and employment growth in the future.

C.1.5 Development of the North East Cam site for 450 dwellings, together with existing commitments elsewhere within the two settlements, would help to deliver 15% of the District’s planned housing supply at this second largest population centre, compared with 15% at Stonehouse (third largest population centre) and 14% at Stroud (largest population centre). The Council believes that, broadly, this represents sensible, balanced growth across the District. At the North East Cam site itself, 450 dwellings located within an area of 17.7 ha would represent development at a density of 25 dph (gross) and 34 dph (net) which is considered reasonable within this location.

C.1.6 The development is anticipated to provide a mix of house types, sizes and tenures to reflect needs identified in the latest Strategic Housing Market Assessment.

C.1.7 The Employment Land Study (CD/C4) notes that a 11.6 ha site at this location is allocated in the adopted Local Plan 2005. Outline permission for 7,500 sqm of B1(a), 10,246 sqm of B1(c), 10,405 sqm and 6,739 sqm of B8 accommodation on 9.34 ha of the allocation has previously been granted but not commenced. The infrastructure costs including a bridge across the River Cam made the scheme unviable at that time. However, bringing forward the site as part of a larger mixed use urban extension, with the housing effectively cross-subsidising the delivery of the employment land is identified in the study as a way of delivering this employment site. This strategy is now being taken forward by the Council and the promoters of the site.

C.1.8 In terms of type of provision, Policy SA3 and supporting text refers to B1, B2 and B8 land. The Employment Land Study states that local agents identify that there is a longstanding demand for small industrial units in Cam/Dursley, but the lack of available stock has meant businesses have to look elsewhere. Demand for employment use is seen as being sourced from existing businesses in Cam and Dursley but approaches have also been received from companies currently in Stroud and North Bristol. Proximity to the mainline railway station with good links to Bristol and provide opportunities to look at office accommodation.

3 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley C.1.9 Other proposed uses on site include accessible greenspace, formal playing space and changing rooms / community building to reflect local standards of provision for this scale of development . The River Cam runs through the site and provides opportunities for enhanced landscaping and walking and cycling routes to provide a structural linear park and to complete the Cam and Dursley Greenway route linking Box Road and the station to the north, with access to the local centre to the south and beyond to town centre facilities at Dursley.

C.1.10The Council has fully considered the range of potential impacts of the development, existing site constraints and infrastructure requirements during the selection of the site and the drafting of Policy SA3.

C.1.11The Infrastructure Delivery Plan (IDP) (CD/C6) and Refresh (PS/E23) involved consultation with service providers to identify the infrastructure required for the North East Cam site and the results of this work have fed into the wording of Policy SA3 and supporting text. The IDP Refresh has not identified any infrastructure constraints that would restrict delivery of the level of growth at Cam within the indicative timescales (section 6.2). On site provision for community and physical infrastructure would be required, together with contributions towards off site primary and secondary education, local community services and transport improvements. If a decision were taken to increase the allocation to higher growth levels (for example 750 dwellings), this may require the site to accommodate a new local primary school. Further investigation would be required, taking account of the County Council’s current review of local standards and a site specific accessibility assessment.

C.1.12The Junction Capacity Assessment (PS/E22) has been prepared for the Council working closely with the Highways Agency (now Highways England) and Gloucestershire County Council. The Assessment concludes that the Local Plan allocated sites can be accommodated on the highway network when the identified mitigation schemes are provided. The allocated sites will need to fund the cost of the mitigation schemes in order for the highway network to accommodate the development. The conclusions for those junctions nearest to the North East Cam site, assuming development of up to 750 dwellings, include:  The A38/St. Johns roundabout (Junction 7) is currently operating within capacity and with the Local Plan development traffic, will operate well within capacity in 2031 and does not require mitigation;  A38 / B4066 (Junction F) and A38 / B4066 (Junction G) are currently operating within capacity but with the Local Plan development traffic, mitigation will be required.  A4135 / B4060 (Junction H1) and A4315 / B4066 (Junction H2) within Cam and Dursley are already operating over capacity and with the Local Plan development traffic, mitigation will be required.

C.1.13Further work to apportion impacts and consequentially costs of mitigation between the allocated sites is being finalised. Highways England has also requested additional work to examine the impact of the Local Plan on the M5 Junction 14, located to the south west of Cam within adjoining South Gloucestershire, which is expected to be close to capacity in 2031. The findings indicate that with the Local 4 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley Plan traffic the junction can accommodate approximately 12.5% additional background traffic before operating over capacity. As a result of the Junction Capacity Assessment and amendments to the Local Plan at the Proposed Changes stage, Highways England has removed its objections to the Local Plan (see REX/B05).

C.1.14A small part (approx 8%) of the North East Cam site comprises floodplain (Zones 2, 3a and 3b) along the banks of the River Cam watercourse. The Flood Risk Sequential Test Update document (PS/E25) summarises the flood risk data contained within the SFRA 2 (CD/D3) and concludes that the sustainability benefits of growth in this location outweigh the limited flood risk. Policy SA3 and supporting text seek to reduce the risk of flooding by improving flood flow pathways and by identifying open space for flood storage. In terms of wastewater and sewage matters, works are already planned at Coaley sewage treatment works adjacent to the site and no future capacity issues are identified. The Environment Agency was actively involved in the drafting of Policy SA3 and supporting text and Proposed Changes PSC039 - PSC043 and supports the revised policy wording (see REX/B02 and Proposed Changes Rep 151). The latest SA Addendum Report (REX/B15b) comments that Policy SA3 and supporting text include a number of policy requirements to ensure that flood risk and water resource/quality impacts are avoided and opportunities realised (para. 12.12.8).

C.1.15The SA Report (CD/C4a) identifies that development at North East Cam may be somewhat sensitive in biodiversity terms as it is adjacent to the River Cam. However, the opportunities that the creation of a linear park provides to maintain or enhance the river as an ecological corridor are recognised, as well as opportunities to provide residents with good access to nature (para. 15.3.4). Both the Environment Agency and Natural England have been consulted on the policy wording in the plan and are supportive of Policy SA3 as amended by the Proposed Changes.

C.1.16The Landscape Appraisal Study (CD/D14) confirms that the site lies within a parcel of land identified as having medium sensitivity to change, where key characteristics of landscape are susceptible to change and have value as a landscape resource. The study concludes that “Some views to elevated AONB uplands to the south available, but generally the topography orientates to the north west resulting in some locally extended views over the lowland plains and a stronger visual association with the urban area of Cam” (para. 3.15). To maintain the landscape setting of Cam and Dursley, to minimise development having an impact on long range views across the area to Peaked Down and Cam Long Down and to the AONB escarpment, the policy requires structural landscaping to provide a green buffer along the line of the 50m contour, beyond which no development will occur. The SA Report (CD/C4a) concludes that “there is no reason to suggest that a 450 home development cannot be accommodated given the potential for mitigation (e.g. through design and the ‘structural landscaping’ measures listed in Policy SA3)” (para. 15.8.1).

C.1.17In terms of deliverability, the site is being actively promoted by the site owners through the plan making process and pre-application discussions are underway. The latest housing trajectory prepared by the Council in Appendix 2 of the Housing 5 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley Statement (REX/B01) assumes that the North East Cam site will be delivered by 2021/22 and progress to date indicates that this is not unreasonable.

C.1.18The Draft Plan Viability Study 2013 (CD/F19) assessed the impact on viability of policies in the emerging Local Plan and concluded that the allocated sites, including North East Cam, “generate a Residual Value that is substantially above the existing use value but not in excess of the viability threshold methodology used in this study. It is important to note that all the infrastructure costs have been allocated to the residential element of the sites and that the full affordable housing targets are being met. These sites represent a large proportion of the new dwelling required over the plan period and it is not necessarily appropriate or possible to consider such large and complex sites in what is a high level study based on relatively little information.” (para. 10.37). The Study concludes that whilst the promoters of these sites are actively pursuing these developments and have provided assurances that these sites are deliverable, the Council and promoters should work together to ensure viability (11.17). The Council has continued to meet regularly with the promoters of this site and pre-application discussions are taking place. The Council considers that the site will come forward in a timely manner.

e. Do the Guiding Principles (including the proposed changes) provide sufficient strategic guidance for the future development of the area?

C.1.19The Guiding Principles have been developed from the early stages of plan making where the Council prepared “area profiles” and consulted local communities on the key issues within their areas. The Council considers that these identify the main strategic matters for the eight parish cluster areas. Development that takes account of these guiding principles is expected to contribute to the delivery of the mini- visions.

C.1.20The Guiding Principles are not intended to cover every land use, nor to provide the detail more appropriately set out within the policies and supporting text. It is not the intention that a development brief for North East Cam is written primarily with the Guiding Principles in mind. Instead, the role of a development brief is to set out how Policy SA3 and other relevant policies within the Local Plan will be implemented.

C.2 Should these settlements accommodate a larger scale of development and/or additional development sites?

C.2.1 As stated above, development of the North East Cam site for 450 dwellings, together with existing commitments elsewhere within the two settlements, would help to deliver 15% of the District’s planned housing supply at this second largest population centre, compared with 15% at Stonehouse (third largest population centre) and 14% at Stroud (largest population centre). The Council believes that, broadly, this represents sensible, balanced growth across the District. A significantly larger allocation at Cam and Dursley, or additional allocations, in preference to the other first tier settlements, may represent too large a proportion of future growth in the District.

6 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley C.2.2 The Council has tested higher housing growth levels at North East Cam (up to 750 dwellings) if required. This would require additional land that is available adjacent to the site on the southern and northern extremities (8.6 ha). If higher growth is envisaged, taking into account this additional land, housing densities of 28 dph (gross) and 37 dph (net) would be required. A larger scale of development would require a proportionate increase in infrastructure on site and potentially a new primary school (see above), but otherwise could be accommodated and the latest SA Addendum Report, Infrastructure Delivery Plan Refresh and Junction Capacity Assessment have all tested this higher growth level at North East Cam.

C.2.3 Other sites around Cam and Dursley have been considered during the plan making process. The Council believes that no other site provides the benefits that a large allocation at North East Cam provides in terms of bringing forward housing and employment together with good links to the local centre and the railway station. Other sites are either too small, have an adverse landscape impact, or will not deliver employment development in an appropriate location.

7 Stroud District Council: Stage 2 Hearing Statement: Matter 3C. Making Places – Cam and Dursley