Contents
Introduction 2
1a) Flooding and Sewerage: Planning 6
1b) Flooding and Sewerage: Fairford 9
2) Transport Assessment 16
3) Education 22
4) Employment 24
Conclusion 28
Appendices
Appendix 1 Letters and emails 30
Appendix 2 Maps 48
Appendix 3 Other documents referred to in the submission 54
Appendix 4 Minutes of Meetings 56
Appendix 5 Extracts from Archive Records 83
Appendix 61 Environment Agency Fairford Flood Report 2008 87
Appendix 7 Fairford Forward Traffic survey Results 130
Appendix 82 Ground Water Levels 141
Bibliography 142
1 The original numbering of this paper remains unchanged and so does not follow the sequence of this document 2 The data in this appendix has been sent as a separate file, ‘2213318 Appendix 8’
Introduction3
The National Planning Policy Framework - Communities and Local Government Committee Section 4 21 December 2011
▪ Sustainable development is development that meets the needs of the present without compromising the ability of existing communities and future generations to meet their own needs. It is central to the economic, environmental and social success of the country both that these three aspects of development are addressed positively and equally and that planning both serves to protect and to enhance and add value to the environment. This is the core principle underpinning planning. ▪ Policies in plans and decisions on development should be assessed against the principles that the nation and areas within it should live within their environmental limits; should achieve a sustainable economy and should seek to ensure a strong, healthy and just society.
Context
Fairford is a small town in the Cotswolds which has been growing slowly but steadily since the Second World War4. Over the years we have accepted the inevitability of development and have welcomed the new residents that new housing has brought. However, the gradual expansion in housing over the past half century has not been matched by improvements to the infrastructure of the town and it is this failure to modernise and improve many of the facilities over time that makes further development unsustainable. At the moment, even before recent developments of over 170 new houses are complete, Fairford is exceeding the environmental limits of the existing infrastructure.
The Case
We fully support the Cotswold District Council (CDC) reasons for refusal of this application. There is no doubt that the entrance to the town and the effect on the Grade 2 listed Burdocks would be highly detrimental. The emerging local plan requires that Fairford ‘will retain its green character’5 but the houses under construction (Bloor and Linden Homes) to the north of the A417 have already had a damaging effect on the entrance into the town; were the Gladman proposals to be approved, the harm would be compounded, and the rural entrance to an old, medieval market town would be destroyed – irrevocably. As our MP, Geoffrey Clifton-Brown has written, ‘it would be a tragedy for the Nation if the level of development in the Cotswolds becomes
3 Please note that all the page references in these footnotes refer to the original document number, not the digital, pdf scrolling number 4 See Appendix 2, Maps, 2.1 A series of maps showing the development of Fairford, p. 48 5 Emerging Local Plan: Second Issues and Options Paper, 6.4, para. 6.26. unsustainably overdeveloped because the damage done will be impossible to reverse.’6 The risk of damage to the quality of the entrance to the town has been tacitly acknowledged by CDC in that they have not included the site in their SHLAA and it is well beyond the development boundary of the town.
However, significant though they are, these reasons do not include any consideration of the fact that the development is simply unsustainable, and in this respect the CDC has failed in its duty to protect the town from unsustainable development. A series of applications for large developments have come before the CDC Planning Committee and no account whatever has been taken of the cumulative effects of so much development over such a brief period of time, not only on the capacity of a community to absorb so many new residents in such a short period of time but also on the capacity of a creaking infrastructure physically to support the needs of such an enlarged population. The town has, quite simply, outgrown the existing infrastructure and is unable to support this additional housing. It is certainly the case that this development will compromise the ability of our existing community and of future generations of Fairfordians to meet their own needs.
Fairford in the Emerging Local Plan7 Option 1. Fairford is identified as a key local service centre8, after Cirencester (1) then after Tetbury, Moreton-in-Marsh, Bourton-on-the-Water (2) – a third tier town Option 2. Fairford is identified as a key local service centre, after the main towns, Cirencester, Tetbury, Moreton-in-Marsh, Bourton-on-the-Water. Option 3. Fairford is identified as a minor service centre9 together with Lechlade, Northleach, Stow-on-the-Wold and South Cerney, after Cirencester (1) then after Tetbury, Moreton-in-Marsh, Bourton-on-the-Water, Chipping Campden (2) In none of these cases could Fairford be described as a principal settlement10 in any usual understanding of the word ‘principal’11.
Infrastructure12 Systems for sewage treatment and disposal Historically Fairford has suffered from flooding, from river, sewers/drains and surface water. The personal, social, and economic consequences of flooding are severe and widespread, and must be given due consideration in all planning matters. The sewage flooding risk in Fairford has been officially acknowledged for several years to be at an unacceptable ‘significant risk’ level.
6 Letter to Nick Boles Esq MP – Appendix 1: Letters and emails 1.1, p. 30
7 Whilst it is accepted that the Emerging Local Plan has not yet been adopted, the documents supporting the Gladman application have made extensive use of the plan and we therefore consider it legitimate to do the same. 8 Emerging Local Plan, Settlement Hierarchy Topic Paper, Section 5.16 9 Ibid, Section 5.32 10 Cotswold District Council, Statement of Case. Section 8a Officer’s Assessment: Housing land supply and the principle of the development proposed in this location, p. 16 11 Chambers Dictionary. Principal = ‘1. Highest in rank or importance 2. Chief, main’ 12 For the purposes of this paper, ‘infrastructure’ does not include gas, electricity or telecoms The current system was installed in the 1943 in preparation for the then new Fairford Air Base. This was a combined sewage and surface water system in which both sewage and surface water from the existing town drain into the same system. The main sewers now lead to pumping stations at Horcott in the west and Moor Farm in the east. From there it is pumped uphill to the treatment plant near the RAF base. After many sewage- flooding problems, the Moor Farm pumping station was upgraded by Thames Water in 2006 to cater for a population equivalent of 4222. In the major flood incident of 2007 the system failed, and there was extensive sewage flooding which has been repeated in subsequent years. Population is already 3500 - 4000, and with the 175 houses already under construction, will exceed the limit. Thames Water has agreed that, ‘the existing waste water infrastructure cannot accommodate the needs of the proposed development.’13 (see Section 1)
Mains Water It is accepted ‘the network has insufficient capacity to supply the proposed development’14. A sufficient supply of clean water is surely a basic right. Consequences of a lack of capacity to deliver mains water include reduced pressure and even intermittent flow; already some properties suffer from low water pressure. Significant engineering would need to be undertaken to improve capacity. The inadequate supply of water would affect schools as well as residential housing. (see Section 1)
Transport The A417 runs through the centre of the town, the route unchanged since medieval times. Narrow, at times down to single lane traffic, it cannot be improved. Plans (and a route) for a by-pass were abandoned in the 1990s, the land sold off. The only possible by-pass route now is the Spine Road to the A419 which, however, has its own problems: it is unimproved over long stretches; there is no prospect of weight restrictions through Fairford; and lorries coming from the west would still need to travel through the town. (see Section 2) It should also be noted that all development tends to follow the line of the main road in an undesirable ribbon development pattern since the area to the north of the town is AONB, the Ernest Cook Trust estate and to the south is floodplain.
Primary School The present school was built in the 1980s, just before a major development in the north of the town. It replaced a village school which had grown to such an extent that it was largely a collection of portacabins. In the past thirty years pupil numbers have continued to increase and it is now full to capacity and residency in Fairford is no guarantee of a place at the local school. (see Section 3)
Surgery The present surgery moved from a residential building in the 1990s. It forms part of a small development, Keble Lawns. As such it is hemmed in on all sides with no physical capacity for expansion. Parking, always limited, is at critical levels and the overflow now causes a significant problem for residents of the estate. Since its construction two sizeable sheltered developments have been built in the town. Although NHS England have stated that the surgery is able to cope with the increase in population which would result from all the proposed developments, repeated Freedom of Information requests
13 Cotswold District Council, Statement of Case. Section 4, ‘Observations of Consultees’, p. 12 14 Ibid, p. 12 have failed to provide any information about how this assessment was reached15. We are therefore unable to challenge their figures or analyses, but genuine concerns remain about the rigour of their investigations into the capacity of Fairford Surgery to cope with increased population.
Employment Traditionally all employment was local but this has been transformed in recent times. Increasingly, local employment opportunities have closed down and residents have had to travel to work. Such opportunities as do exist are limited and cannot support the expected growth in population - which could be as high as 30%. (see Section 4)
Recent Developments in Fairford Over the past two years Fairford has been the focus of several large-scale planning applications.16 • June 2012: 37 houses on Pip’s Field, Cirencester Road, Fairford (under construction) • March 2013: 127 houses on land west of Pip’s Field, Cirencester Road (under construction) • November 2013: 120 houses on land south of Home Farm, Cirencester Road (application refused now the subject of this appeal) • March 2014: Initial 4 houses at Land at Waiten Hill Farm (pending) 14/01221/OUT. This application ‘seeks to establish the principle for residential development at this site’17. There is a phase 2 for the site (number of houses unspecified) which includes a hammerhead road layout, suggesting further development beyond phase 2. • April 2014: 120 houses on land at London Road (application pending decision) 13/03093/OUT • May 2014: 22 houses at Sunhill Close/Saxon Way (application approved) 13/05181/OUT In addition, several large holiday home developments have been approved between Fairford and Lechlade, the most recent being a development of 59 ‘pavilions’ on the Lakes at the eastern boundary of the town (09/00882/OUT), together with 63 apartments and 18 more ‘pavilions’ at Milestone House (09/00872/OUT). There are also 106 families already in residence at the Fairford Air Base (reportedly staying for a minimum 5yrs). In total, this adds up to a possible 570 new houses + 106 new families.
Conclusion
The NPPF has always stressed the importance of sustainable development. The recent Ministerial forward to this document defines sustainable to mean ‘ensuring that better lives for ourselves do not mean worse lives for future generations … change for the better’. In the case of Fairford, this development would not only mean worse lives for future generations, but worse lives for the residents of Fairford today. We therefore respectfully request that the appeal by Gladman Developments be dismissed.
15 See Appendix 1, Letters and Emails: 1.4 NHS England, p. 43 16 Where possible, dates given are decision dates 17 Planning Supporting Statement for the Ernest Cook Trust, Section 3.1, Application Proposals, CDC Ref. 14/01221/OUT, p. 5 1a) Flooding and Sewerage: Planning
Local flood risk is defined in the Flood and Water Management Act as flooding from surface run-off, ordinary watercourses and groundwater.
National Planning Policy Framework (NPPF)
It is the responsibility of the Local Planning Authority to assess the risk of flooding to new developments, from both fresh water and sewers, and assess whether there will be increased risk to others. The Government’s proposals for forward planning of flood management over the next 20 years advocate a holistic approach to achieve sustainable development. Central to the government’s strategy is protection of the functional floodplain and diversion of development to appropriate areas. The NPPF directs LPAs to ensure that planning applications do not have unacceptable adverse impact on increased flood risk and on impacts on the flow and quantity of surface and groundwater. In assessing this risk it should seek advice from the Environment Agency, and other relevant flood risk management bodies such as the Lead Local Flood Authority and water companies. The NPPF directs: ‘Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards’18 The NPPF has replaced Planning Policy Statement 25 'Development and Flood Risk'. However, the policy principles remain unchanged. Supporting Technical Guidance has been issued and the associated Practice Guide remains in place until Government chooses to replace it. PPS 25 sets out a plan led approach to flood risk. It confirms that all forms of flooding and their impact on the natural and built environment are material planning considerations. It clarifies the sequential approach (a process that minimises risk by directing development to areas of lowest risk), matches types of development to degrees of flood risk and strengthens the requirement to include FRAs at all levels of the planning process. Regional planning bodies and local planning authorities (LPAs) should, amongst other things, reduce flood risk by safeguarding land from development that is required for current and future flood management e.g. conveyance and storage of flood water and flood defences. Planning Policy 18 states that any development should be commensurate with the infrastructure and services available.
Gloucestershire County Council GCC is the Lead Local Flood Authority and is responsible for taking the lead in managing flood risk from local sources, including surface water, groundwater and ordinary watercourses. Their Local Flood Risk Management Strategy says that ‘without effective planning policy there is a risk that the increase in hard standing and impermeable surfaces associated with development will increase surface water runoff and hence the risk of flooding. It is imperative that surface runoff and flood risk are fully
18 National Planning Policy Framework 2012, p. 23 para. 100 assessed as part of the development of Local Plans and in determining planning applications to mitigate this risk’.19 It includes Strategic Objective 3: ‘Avoid inappropriate development and ensure that new development does not increase flooding elsewhere. It states that Local Planning Authorities will use the best available information on local flood risk to inform spatial planning’20 and with reference to Fairford states, ‘may be some residual surface water flood risk which will be considered by CDC.’21 GCC does not exercise responsibility for surface water in the Fairford district, leaving this to the local Water Authority, Thames Water, and is not a consultee for planning.22
Environment Agency The EA is responsible for managing flood risk from main rivers, reservoirs and the sea. It concentrates on fluvial flooding but also has a strategic overview role. The EA does not exercise responsibility for surface water in the Fairford district, leaving this to the local Water Authority, Thames Water.23
Thames Water Thames Water is a non-statutory consultee in planning matters, and has confirmed that the sewers are full and the proposed development can not be accommodated by existing infrastructure, and also that the water supply is insufficient for 120 more houses. In addition, Fairford is not currently a catchment for which Thames Water is developing a plan / strategy.24
Cotswold District Council It is the policy of Cotswold District Council - Policy 49 (Planning Obligations and Conditions) that in order to achieve sustainable development, proposals will only be permitted if the social, economic and environmental impacts of the development are satisfactorily mitigated, or compensated for, and the service and infrastructure needs are met fully. Cotswold District Council’s Local Plan considers flood risk through Policy 6 – The Water Environment. The Policy stresses the following objectives relevant to the area: ‘Development will not be permitted within or affecting river valleys and their tributaries: if it would result in an unacceptable increase in flood risk in areas downstream due to additional surface water run-off, or upstream due to obstruction of the river's floodplain, which could reduce its capacity at times of flood’ 25. The CDC Strategic Flood Risk Assessment stresses the importance of storage in catchment areas, and the need for Surface Water Management Plans and Catchment Flood Management Plans. It notes that the accuracy of flood zones within the district is
19 Gloucestershire Local Flood Risk Management Strategy February 2014 (Main Document) 4.3.2, para. 82, p. 29 20 Gloucestershire Local Flood Risk Management Strategy, Summary Document, p. 7 Table 2 21 Ibid, p. 8 Table 3 22 See Appendix 1 Emails and Letters, 1.1 Flooding and sewage, 1.1.3 Emails from Gloucestershire County Council, p. 38 23 See Appendix 1, 1.2 Flooding and Sewage, 1.2.1 Emails from the Environment Agency, p. 32 for general points 24 See Appendix 1, 1.2 Flooding and Sewage, 1.2.2 Emails from Thames Water, p. 34 25 Cotswold District Local Plan 2001-2011, Adopted April 2006, Section 2, The Cotswold Environment: Protecting our Natural Environment, Policy 6 The Water Environment, p. 14 poor, particularly within the Cotswold Water Park, and gives detailed guidance on SUDS systems. River Coln: ‘Consultation with EA staff has indicated that there is a complex relationship between the River Coln, Court Brook (draining from Fairford) and existing gravel pits. This is an area where development is underway and is also proposed. It should be highlighted that there is a need for further modelling work in this area.’26 Flooding from sewers as recorded in the Severn Trent Water, Wessex Water and Thames Water DG5 register, for GL7 district this shows only 1 property affected and low risk27. This does not accord with information in The Pitt review, an independent review into the 2007 floods. ‘Some of the areas worst-affected by surface water flooding included Moreton-In-Marsh, Fairford and Whelford. Additionally, Thames Water has identified nine areas where properties were flooded internally by sewers (Fairford, South Cerney, Ampney St Peter, Ampney St Mary, Upper and Lower Slaughter, Moreton-in- Marsh, Bourton-on-the-Water, Quenington).28 Also: ‘On 20th July 2007 Exceptionally heavy rainfall fell onto already saturated ground resulting in quick, widespread flooding from a variety of sources, not just watercourses. As well as extremely high river flows, it is important to note that surface water, sewer and groundwater flooding played a considerable role in the summer flood event, adding to the complications. Drains and sewers were overwhelmed by the intense and prolonged rainfall, rapidly causing flooding.’29
Surface Water and Sewerage Management Plan for Fairford The Local, District and County councils have all been approached with requests for a surface water and sewerage management plan for Fairford, based on a thorough investigation of the hydrology and water flow patterns of the River Coln and adjacent lakes. Until this has been done, on-paper compensation and mitigation steps may not be adequate or appropriate. For example, there is much reliance on SUDS and infiltration in areas where groundwater levels rise to the surface in wet seasons, making these techniques unsatisfactory. Groundwater levels in Fairford have a huge variation because of the properties of the gravel and underlying clay. E.A figures are included for a borehole SP10/105 (25). These show a strong seasonal variation with much higher levels in the winter with the ground waterlogged at times. Figures ranged from a high of 81.280m AOD to low of 79.537m, a difference in groundwater level of 1.743m, during a 14-month period.
26 Cotswold District Council, Strategic Flood Risk Assessment, 2008, Table 4.3 Inaccuracies with Flood Maps within Cotswold District, p. 48 27 Cotswold District Council, Strategic Flood Risk Assessment, 2008, Table 4.4 Flooding from sewers as recorded in the Severn Trent water, Wessex water and Thames water DG5 register, p. 50 28 Pitt, Sir M, Review: Learning Lessons from the 2007 Floods, 29 Ibid. 1b) Flooding and Sewerage - Fairford
NPPF Meeting the challenge of climate change, flooding …
▪ . Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards (p.23 para. 100) ▪ local planning authorities should: … set out environmental criteria … against which planning applications will be assessed so as to ensure that permitted operations do not have unacceptable adverse impacts on the natural or historic environment or human health, including from increased flood risk, impacts on the flow and quantity of surface and groundwater …; and take into account the cumulative effects of multiple impacts from individual sites and/or a number of sites in a locality (p. 33 para. 143) ▪ To promote a strong rural economy, local and neighbourhood plans should … promote the retention and development of local services and community facilities in villages such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship. ▪ Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. (p. 9 para. 30)
The Fairford Catchment
Fairford, as its name suggests is a town which grew around a river crossing. It is a small town in a narrow river valley whose geology makes it unsuitable for expansion. It is located in the lower catchment of the River Coln, which bisects the town roughly from north to south then flows south east to join the River Thames at Lechlade, about 6.5 km away. Fairford is situated on the boundary where the oolitic limestone of the Cotswold escarpment gives way to the gravel beds of the upper Thames Valley. The limestone is predominantly permeable and absorbs rainwater which then discharges slowly into the river. In this area there are extensive gravel deposits over a base of Oxford clay. The River Coln drains a catchment area of approximately 135 square km. i.e. all the rain which falls in that area runs through the valley around Fairford, either in the river or as ground or surface water, draining with the slope to the S and E. Upstream, the Coln flows over permeable limestone which absorbs rainwater and then takes time discharging it into the river. Springs arising at the boundary contribute further to flow/levels at Fairford. Downstream are gravel beds over underlying Oxford Clay30.
30 EA has complete records of this since there are several boreholes with automatic recording of levels 24 hours/day. Recent figures are included (Appendix 8: Ground Water Levels) for a borehole Sp10/105 shown on map: Appendix 2, Maps, 2.3 Lakes and Watercourses in the Fairford Catchment, p. 53 Rainfall run-off is much quicker from clay because clay is impermeable. In dry seasons, the gravel is permeable and free draining, with rapid infiltration. In wet seasons the rains collect and fill up from the clay base and groundwater levels become very high, often waterlogged in winter. In addition, once the floodwaters from heavy rainfall move downstream from Fairford it is very likely that they will be followed by additional waters from the permeable section of the catchment upstream. This means that high groundwater levels are likely to persist for some time. Further downstream from Horcott Farm on the left bank there are extensive worked-out gravel pits which now form a series of 5 interlinked lakes, acting effectively as a natural water storage area. The Court Brook, a minor watercourse which was Fairford’s original town sewer, runs at a lower level than the river. It is dry most of the time reflecting groundwater levels but in wet seasons collects overflow from the river and channels it into the lakes. The flood plain at Fairford is significantly urbanized and rainfall on roofs, pavements and roads runs off quickly with little absorption into the groundwater. Every bit of impermeable material from development added to the river basin displaces an equivalent amount of water and prevents rainwater soaking into the ground, causing it to run elsewhere as surface water. The whole area is part of the Cotswold Water Park.31
Recent history In July 2007, Fairford suffered severe flooding; the river spilled over its banks and 84 houses were flooded, many contaminated with raw sewage. As a consequence, the Environment Agency prepared an extensive Flood Alleviation scheme for Fairford, designed to protect residential properties and bring them up to the standard of a 1 in 100 years’ probability of flooding. This alleviation scheme was implemented in 2013/2014, but it does not offer protection against the risk of drain or sewage flooding, and the EA has explained that they are not funded to provide solutions for the foul or surface water drainage network.32 The Environment Agency report into the July 07 floods concludes ‘In many areas, including Fairford, flooding problems have increased due to man activity and development within the floodplain which results in greater run-off and an overloaded drainage system.’33 Since then, the river has been contained as far as 20m beyond Dilly’s Bridge but the sewerage and surface water problems have increased. Development and population have increased to the point where the sewers and pumping system are at full capacity and there is no room for surface water run-off in storm conditions. During the wet winter December 2013 to March 2014 many parts of the town suffered from serious sewage and surface water flooding problems. Sewage spilled from drains and manholes forming
31 See Appendix 2 Maps, 2.3 Lakes and Watercourses in the Fairford Catchment, p. 53 32 EA’s answer to query as to whether the flood alleviation scheme will improve surface water/sewer situation. Appendix 4, Minutes of Meetings p. 56 ‘Our proposed scheme is to protect Fairford from river flooding, and aims to retain the flood waters within the channel or natural floodplain areas. We will understand how our scheme relates to other forms of flooding such as surface water and highways drainage, but we are not funded to provide solutions for the foul or surface water drainage network. We will of course provide our assessments and data to others in an effort to assist them with any proposals they may have.’ 33 See Appendix 6 p. 87-129: Anya Bednarczyk, Environment Agency: Fairford Flood Report, July 2007 Floods Review, March 2008, Background, 1.3 Characteristics of the Catchment, p. 6 lakes in the streets, contaminating houses, polluting the river and running into the fields. Many who didn't have actual flooding had their Christmas and New Year period ruined by the inability to flush toilets, use baths, dishwashers, washing machines etc. because of pressure in the drains34. This situation is likely to recur whenever there is heavy or prolonged rainfall.
Fairford’s Sewerage System Fairford does not have a separate system for dealing with surface water; it either runs into the sewers (before being pumped up to the sewerage treatment works) or drains into the ground and percolates with the gradient into the river and lakes to the south east. The Thames Water Sewer Map35 shows this but does not acknowledge that most of the sewers are combined sewage/surface water. The present sewage system was built in 1943 to serve the new wartime air base (now RAF Fairford). From the Moor Farm Pumping Station, sewage and surface water is pumped across the river and uphill to the sewage plant next to the air base. When first built there was an emergency overflow into the river but discharge of untreated sewage into rivers is now illegal36. If for any reason the pump is unable to cope and the onward flow is not maintained, there is nowhere for the flow to go except to back up and then it comes out of the drains. This happens particularly in East End near the pumping station and in the Courtbrook/Moor Lane area where houses were built on the flood plain. After development in Lygon Court in the late 1990s problems became worse. Between 2000 and 2004 there were many sewage flooding incidents and in 2000 and 2003, Fairford Town Council had to provide temporary toilets in the Courtbrook area when the sewers were so full of surface water that they ceased to operate. Plans were made to upgrade the system and in 2006 Thames Water installed a new pump and upgraded sewers at the Moor Farm pumping station. At the same time an additional sewer was added down Cinder Lane and a new sewer was installed to serve the west of the town, going directly to the treatment plant, pumped from Horcott. The works were built to a design horizon of 2021 based on predicted growth, and were intended to accommodate a population equivalent of 4222. However, within a year of the upgrade, in July 2007, its design standard was exceeded due to the extra heavy rainfall and river overspill - and the system failed.
Sewage flooding risk Concerned residents have been trying for many years to persuade the authorities to take the surface water and sewage flooding risk in Fairford seriously. There has been so much public concern about sewage and flooding matters since 2011, that the local MP, Geoffrey Clifton–Brown has held regular meetings to discuss the issues.37 Senior planning officers were present at these meetings and gave empty assurances that they were aware of the infrastructure problems and were consulting with Environment Agency and Thames Water, and that developments would not be allowed which would increase flood risks for inhabitants.
34 See Appendix 3, Other documents referred to in the submission, Flooding incidents in Fairford: Winter 2013 – 2014, p. 54-55 35 See Appendix 2, Maps, 2.2 Thames Water Plan of Fairford Sewers, p. 53 36 In extreme weather events, Thames Water do discharge untreated sewage into the river as happened in the winter of 20013/14 37 See Appendix 4: Minutes of Meetings, p. 56 onwards For example, in July 2011 ‘Huw Thomas on behalf of Thames Water said that they always look at planning applications and are consulted. He is confident that the current sewage system in Fairford will be sufficient up to 2025. There have been no reports of sewer flooding since the last meeting. “Sewer flooding in the 21st century is unacceptable.”’ In October 2012: ‘Q. There is a fear that all the work to protect properties from flooding in the town will be undone by an unsustainable amount of new development. A. Dave Ludford explained that the EA works closely with the District Council on all planning applications. He confirmed that the EA look very closely at all planning applications made in a flood plain. – EA does have a joined up approach with the DC – we consult on any application for significant developments.’ Again October 2012 ‘There is a general consensus that the current sewage system to the east of the town could not cope with the increase in capacity, and that this is something which must be seriously considered by the planning office.’ Yet the position has been allowed to escalate to the point where recently there has been widespread sewage pollution throughout the town. In November 2011, Councillor Mark Wardle reported to the Town Council that he had been in contact with Thames Water and was given the figures that in the east of the town the sewage system is capable of dealing with a 1 in 15 year flood, compared with OfWat’s minimum requirement of 1 in 20, i.e. there was already an unacceptable sewage flooding risk.38 Despite the acknowledged significant flood risk, planning officers have continued to support development regardless, often recommending consent without sewage conditions. Already there are more than 300 houses under construction or for which consent has been granted in Fairford, including 170 on the N side of Cirencester Road, opposite the proposed Gladman site. In addition, consent has been given for 140 large holiday homes plus leisure complex, on 2 sites on 3 of the lakes which serve as Fairford’s natural flood reservoir39. Full consent for these was granted in June 2013, without conditions for sewage provision, although Thames Water stated that although they had agreed in April 2009 to accept sewage from this site, they now felt it likely that in storm conditions the Moor Farm pumping station would not be able to cater for the additional flows.40 Sewage from this development housing more than 500 people will far exceed the design capacity. At the same time, large areas of impermeable material will greatly decrease the flood water storage capacity of the lakes, increase surface water run-off and block natural flow channels. There are now more than 440 houses under construction or with consent granted to join Fairford’s already full sewers, which will bring the population well over the 4222 design limit of the system, leaving no room for surface water in storm conditions, in a situation where sewage flooding is not just a risk, but a reality. These developments all now have a legal right to sewer connections. Utility providers have a licence obligation to ensure that any connections to the system comply with all relevant regulations, legislation and engineering recommendations thereby not having an adverse effect on the supply and quantity of supply to existing customers. It is significant that the most recent flooding included parts of Horcott and the failure of the Horcott Pumping Station, not previously affected. Flooding came not from the river but from sewers and it is very likely that the cause was storm water run-off from the current housing developments N of Cirencester Road. Some houses at Horcott continue
38 Fairford Town Council Minutes 8th November 2011. 39 Planning Applications Ref 12/05033/REM and 12/05034/REM, 09/00882/Out and 9/872/Out], Lakes 104,103, 103a and Milestone House, Fairford 40 Appendix 1 Letters and Emails, 1.2.2 Emails from Thames Water, p. 36 to have problems with their drains, and we believe that the current development on the Pip's Field and Cirencester Road sites has contributed to this because the groundwater previously held in the fields is no longer held there but has been diverted to run towards Horcott. It is understood that residents have already reported flooding of their gardens in this new development. Additional houses on the Gladman site would make this situation worse.
The Gladman application Ref 13/03097/OUT
There are many reasons why this site is not sustainable, but the inadequacy of the sewer system and mains water supply is the most compelling.41 Thames Water has made it very clear that the existing wastewater infrastructure is not able to accommodate the needs of the development. The application documents state: • ‘There are concerns in relation to this site, specifically, the current sewerage network capacity in this area is unlikely to be able to support the demand anticipated from this development. The existing foul water sewer network was very close to capacity when the development to the North of this site was considered. • ‘It will therefore be necessary for TW to undertake investigations into the impact of the development by means of a developer-funded impact study. This will determine what upgrades to the existing network are required before the site can be connected to it. • ‘Where there are no surface water sewers in the area, connection of surface water to a foul sewer will only be considered when all other methods of disposing of the surface water have been proven impracticable. In this case, discharge of surface water to the public foul water sewer will increase the level of network upgrading required. A study considering both foul and surface water will take longer than a study considering foul water only.’42 So there will need to be an extensive study to decide what additional sewage capacity will be required, and how it will be provided. Further investigation can only confirm that the public sewer network is full and outdated, the pumps are at the limit of their capacity, the sewage treatment works are inadequate and a major upgrade is required throughout. The last upgrade, carried out in 2006, cost £3.6 million and was several years in the planning. Thames Water’s capital programme up to 2015 does not include sewage improvements for Fairford,43 though they are hoping that money from more housing developments will expedite the process. However, the lead-in time for a major sewage infrastructure upgrade is 5 to10 years. It would be premature to consider conditions for this development before the general infrastructure requirements for Fairford have been determined.
Housing on this site cannot be considered deliverable. Outline planning consent should not be granted, because development has already far exceeded sewage capacity and no further building can be inhabited until there are realistic prospects of bringing the whole sewage system to an acceptable level. Once the study has been completed, there will need to be negotiations to decide what new sewage infrastructure will meet
41 See Appendix 2 Maps, 2.2 Thames Water Plan of Fairford Sewers, p. 53 42 LK Consult Limited: Land at Cirencester Road, Fairford, Flood Risk Assessment and Drainage Strategy, July 2013, Section 3: Information Gathered, p. 5, para. 3.2 43 See Appendix 1: Letters and Emails, 1.2.2 Emails from Thames Water, p 34 requirements, how much it will cost (likely to be many times more than the New Homes Bonus of £0.9 m over 6 years), how and when it will be provided and what percentage of the total cost is necessary and reasonable for the developers to pay. These discussions will be compromised if outline consent has already been granted. Section 106 Agreements cannot be required to secure water and waste water infrastructure upgrades beyond the requirements of the development. It is not the responsibility of the applicant applying for planning permission to remedy existing infrastructure inadequacies within the foul drainage network.
However, it is essential to ensure that such infrastructure is in place to avoid unacceptable impacts on the environment such as sewage flooding and water pollution, and also water shortages and problems associated with low pressure water supply.
Developers have stated in the application, ‘Reference has been made in the pre- development enquiry to the existing foul system being at full capacity, but does not identify any known sewerage flooding problems in the area. The SFRA indicates that the site is in a low risk area for sewer flooding. Therefore, the flood risk associated with this source is considered negligible.’44 However, records from Fairford Town Council45 show that Fairford has suffered sewage problems for almost a century.
These statements by the developers were made before the floods of last winter, but it was pointed out at the time that though the site itself may not be subject to flooding, the development will increase the flood risk in other parts of the town. Replacing 4.3 Ha of permeable topsoil with a housing estate will cause surface water run-off to increase, and run into the sewers. Since the sewers are already full, any major storm is likely to cause further sewage flooding. On paper the proposed SUDS arrangements will mitigate and hold back surface water. In practice, groundwater levels will rise, SUDS will fill up and remain full and surface water will overfill the drains and cause sewage flooding.
The Flood Risk Assessment and Drainage Report prepared by LK Consult submitted with the application is very superficial and makes no attempt to consider the effects on other areas. It claims to demonstrate that foul and surface water drainage will be appropriately managed, but can not demonstrate that adequate foul water capacity exists both on and off the site to serve the development or that it would not lead to problems for existing users. Section j of the application discusses impact on Mineral Extraction. It notes, ‘The available information would suggest that sand and gravel beneath the site could be of around 3.5m thickness and present at depths of greater than 0.6m.’46 This site forms part of a much larger deposit in this area which has historically been subject to working. No attempt has been made to consider the impact of this large amount of gravel on water flow or groundwater levels, though the Mineral Assessment 31 Oct 2013 indicates that the
44 See Appendix 3, Other documents referred to in the submission, Extract from Planning Officer’s report to the Planning Committee with reference to the Gladman Developments application 13/03097/OUT, p. 55 45 See Appendix 5, Extracts from Archive Records, p. 83-87 46 LK Consult Limited: Minerals Review and Qualitative Assessment of Land South of Cirencester Road, Fairford, para. 3 Assessment of the Available Resource, p. 3 material is suitable for founding strata and also for road usage.47 It records that ‘Building control note that there are high groundwater levels in the area, which could be a potential building constraint.’48
The FRA states, ‘A number of Sustainable Urban Drainage Systems are proposed which link to environmental and ecological benefits’49. It ignores the fact that SUDS are ineffective when groundwater levels are high, and fails to demonstrate how the drainage would operate in wet seasons. It records that the ground is very suitable for infiltration techniques, but ignores the fact that the undeveloped site is likely to be providing major water storage capacity, which will decrease on development.
The FRA mentions a stream running to the south of the site and suggests that overflow from the SUDS system and possible storage pond could discharge into this.50 The stream is culverted in parts so could not carry greater flow, and the necessary de- culverting would have adverse impacts on the public footpath. This stream runs into Horcott Lakes and was responsible for surface water flooding last winter, particularly around Mere, Burdocks and adjacent properties; increased flow will increase this flooding. In addition, increased water flows into this stream will have an adverse impact on the biodiversity of the lakes and on Hanson’s Biodiversity Action Plan51, approved by CDC. No account seems to have been taken of this in any Environmental Impact Statement.
Residents have noted that this ditch is dry for most parts of the year but subject to seasonal flooding. It is clearly a flow route into Horcott Lakes, and this should have been considered in the FRA since the development intends to make use of it. The conclusion that the flood risk is considered negligible has no foundation, since adequate arrangements have not been demonstrated for disposal of either foul or surface water.
Conclusion
The unresolved issues of potential sewage and surface water flooding mean that the site is not sustainable for development. • Housing on this site is not deliverable until there has been a major upgrade of Fairford’s sewers and pumping system, unlikely to be within the next 5 years. • The FRA is inadequate and fails to address issues specific to Fairford. • The proposed development of the site is highly likely to increase flooding off site, specifically in the Mere and Horcott area. • Issues relating to the mains water supply have not been addressed.52
47 Ibid, para. 4 Potential Use of Material During Development, p. 3 48 Ibid, para. 2 Site Setting, Hydrology and Hydrogeology, p. 2 49 Planning Prospects on behalf of Gladman Developments, Planning Statement, July 2013, 5, Planning Balance, Climate Change, Flood Risk and Drainage, para. 5.32, p. 22 50 LK Consult Limited: Land at Cirencester Road, Fairford, Flood Risk Assessment and Drainage Strategy, July 2013, Section 7.2, Proposed Foul Drainage, 7.3.3, p. 13 51 Hanson UK Biodiversity Action Plan, Horcott Quarry Site BAP 2009 52 Quotation from MP Geoffrey Clifton-Brown’s website, www.cliftonbrown.co.uk, Fairford Water Supply, ‘Geoffrey Clifton-Brown, has today issued a statement following news that two thousand homes in Fairford, Horcott, parts of Lechlade and Whelford are suffering from discoloured water. Thames Water have circulated letters to the 2,000 affected homes, and In view of the recent widespread flooding incidents causing distress to residents and sewage contamination of roads and watercourses there is a clear need for a surface water management strategy, as well as sewerage management plan for the whole of Fairford. There should be no further major development on this or any other local site until these problems have been addressed.
Vibrant and successful communities need development, but this must be sustainable. NPPF requires the planning system to play an active role in guiding development to sustainable solutions. The proposed development on this site south of Cirencester Road should be refused.
are asking that customers boil water for drinking and cooking purposes as a precaution.’ A statement by Thames Water states, ‘We believe the recent heavy rainfall has washed sediment into the groundwater that feeds the water treatment works at Fairford, leading to the reports of discoloured water.’
2) Transport Assessment
NPPF
• There is ‘a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan making and decision-taking.’ • One of the NPPF Core Principles is to … ‘actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable.’ (Planning Policy Guidance 13 Transport Objectives’ para. 6)
Introduction
The Planning Application by Gladman Developments Ltd (13/03097/OUT) claims that their development meets the NPPF Transport requirements, but evidence, both factual and from actual observations by residents of the road/transport problems in and around Fairford over many years, shows that this assumption by Gladman Developments is incorrect and not based on valid, up to date, information.
This Transport53 section of Fairford Planning Watch’s response to the Gladman Appeal Document details our main areas of concern. • ‘Site Location and Existing Situation’ (2.0) - with particular concern to the lack of reference to the large numbers of existing houses and parking problems in Coronation Street, Horcott Road, Milton Street and London Road.54 • ‘Highway Safety’ (3.0) – lack of knowledge of the actual traffic situation on Cirencester Road, west of Fairford, and reliance on statistical evidence, prior to the recently constructed accesses to the new housing developments on the north of the A417 and to the proposed Gladman Development. • ‘Vehicular and Pedestrian Access’ (4.7, 4.8, 4.9) – reliance on unrealistic assumptions of other methods of transport other than by car. • ‘Transport Planning Policy’ (5.0) which seeks to minimise journey lengths (5.5, 5.6). • ‘Accessibility to Sustainable Modes of Transport’ (6.0) – majority of employment and shopping will not be in Fairford but Swindon, Cheltenham etc. and distances to local shops, schooling and leisure facilities are outside of ‘preferred’ distances’ and along dangerous roads and junctions. Public Transport to Cirencester, Swindon and other centres exists on paper, but, in reality, the timings of the services make them at best inconvenient and at worst, i.e. to/from Swindon railway station, unusable. • ‘Traffic Forecasting’ (7.0) • ‘Highway Impact’ (8.0) – the traffic surveys used, whilst detailed, are taken over either one day or a short period of time. Also the additional traffic usage quoted appears to be, at best, understated and the calculations are at odds with those used for the other new developments in Fairford. The traffic flows shown are also very similar to those identified by the (more comprehensive) survey carried
53 Curtins Consulting: Transport Assessment, Land off Cirencester Road, Fairford, July 2013 54 Ibid, Section 2.0 Site Location and Existing Situation, para. 2.9 p. 7 out for the Fairford Forward programme in 2007, whilst local residents have experienced the large increase in traffic through Fairford over the past 5+ years, especially in vans, large commercial vehicles and very large agricultural tractors/implements.
The following sections detail our specific concerns and observations concerning the traffic situation in and around Fairford and the effect of the proposed Gladman development on this situation. We specifically refer to the points and comments included in the original Gladman Planning Application.
Site Location and Existing Situation
Concerning the junction of Cirencester Rd, Coronation Street and Horcott Road. The Gladman Application quotes: ‘Coronation Street serves a small number of residential properties’ and ‘Horcott serves some residential properties’ and ‘the Horcott Industrial Estate’55
In reality: • Coronation Street and feeding streets (Milton Place, Bettertons Close, Fayre Gardens, The Green and Welsh Way/West End Gardens) hold 178 properties. On Coronation Street most properties open directly onto the street, and on the west side of the street vehicles regularly park nose to tail, up to and beyond the entrance to Bettertons Close, with other cars/vans parked on the east side. In the evening and weekends both sides of the road are often full of parked cars/vans with room for only one car to get by. Vehicles turning into Coronation St from the A417 often have to wait (on the A417) until there is room to pass up Coronation St. New developments have now been approved behind Saxon Way (22 houses) and a decision is pending for Waiten Hill Farm (4 houses to begin with), which will further exacerbate the existing access problems. • Horcott Road, up to the 40mph limit, has 135 properties, including those feeding in from Lakeside and Faulkner’s Close (including the new development on the Industrial Estate). Heavy vehicles regularly use the A417/Horcott Road junction to/from Horcott Industrial Estate and RAF Fairford (which still has military activity and also 106 families living there - working at Brize Norton).
2.10 No mention has been made of the continuous parking on: • north side of Milton St, • outside the Marlborough Arms on the A417/Coronation St/Horcott Rd junction. • south side of London Road between Hyperion House and opposite the Palmer Hall (regularly on double yellow lines and causing serious congestion between the Market Square (High St) and beyond the turning into The Plies.
At peak and at other times, due to the heavy lorries increasingly using the A417 through Fairford, queues of over 20 vehicles at a time form at these congestion points.
The Curtins Report states that the High Street has ‘off street and on street parking bays’ and ‘therefore parking does not reduce the carriageway space available to moving
55 Ibid. 2.0 Site Location and Existing Situation, para. 2.9, p. 4 traffic’.56 It is obvious that the consultants have not been present when, on most days, the bottom of the High Street i.e. close to the junction with the A417, is down to a single carriageway, or completely blocked/seriously restricted, by lorries delivering to the shops e.g. The Co-Op, or by double parking outside the shops at the bottom of the High St. On the Wednesday Market Day, this congestion is further aggravated. The result is regular hold ups on the A417 at the junction with the High Street.
Highway Safety (3.0)
The traffic report57 concludes that the road layout etc. in the past, did not contribute to accidents. However, over the 6 year period reviewed in the planning application there were no major access points onto the A417 in the vicinity of the proposed development, west of Fairford. With three new major junctions now being planned, opening onto the Cirencester Road, serving almost 200 households, with the downhill entrance and sweeping bend into Fairford (at the bottom of the hill) and with the proposed pedestrian island, a very dangerous situation is now being introduced, dangerous even if a reduced speed limit is introduced.
We believe that the Road Safety Audit undertaken on 21 May 2013, by The Safety Forum for the proposed site access, is not a true representation of the impact of the development on road safety since it was undertaken only in front of the site (not at any other junction), between 14.00-14.40, hardly peak time, and in fine, dry weather with excellent visibility.
Development Proposals (4.0)
Vehicular Access58 The average speed observed during the 7-day survey was 52.8 mph coming down the hill from Cirencester into a bend with restricted visibility. However, it does not identify the types of vehicle – important given the high number of large goods vehicles using the A417 through Fairford. Most critical, are the problems during wet weather at the bottom of the hill and the on the inside of the bend on the A417 approaching Fairford, which, again, are not mentioned in the document. Due to the topography surrounding the area, there is considerable water run off from the fields which frequently results in pooling of water on the inside of the bend and across the road59. Braking distances (and concentration) are therefore affected and with vehicles now slowing to enter (and exit) the potentially three new developments, a very dangerous situation will result.
Pedestrian Access60
56 Ibid. para. 2.14, p. 4 57 Ibid. 3.0, Highway Safety, para 3.2-3.9 p. 5 58 Ibid, 4.0 Development Proposals, Vehicular Access, para. 4.7, 4.8 59 The width of the road drains into the stream leading to Horcott Lakes 60 Ibid. Pedestrian Access, para. 4.9 It is not mentioned in the Application, that all pedestrians and cyclists will have to cross the A417 to reach the major facilities in Fairford. Even with a pedestrian island it will take a very brave mother to cross with her children, given this is an A road (effectively used as a Trunk road) with 40MT lorries regularly using it. Cycling on this road is also extremely dangerous, even for experienced cyclists.
Transport Planning Policy (5.0)
Minimise journey lengths61 It is stated that the development supports and conforms to the sustainable transport policies of NPPF. However, it is very difficult to see how this is the case: 1) The majority of employment will be in Swindon, Cirencester, Oxford, Gloucester and other main centres – meaning extensive car journeys. Times of buses to Swindon and Cirencester are not appropriate for working people. 2) It is already very difficult to park in Fairford and therefore most shopping is presently undertaken and will continue to be, in Swindon, Cirencester etc. Also people will not walk (preferred maximum distance is 800m) or cycle the 1250m62 into Fairford (neither can they carry large amounts of shopping) and therefore even more people will drive to the surrounding large towns and supermarkets and/or try to park in Fairford. 3) Schooling. With the dangers from traffic on the A417 and the distance (around 1.4 miles), most parents will take the children to school by car. Parking at the school is already inadequate and dangerous with up to 30 cars waiting at the end of school and school buses entering/leaving the school. 4) Leisure. Any leisure activities are either at the other end of Fairford +/- 1m, (Leisure Centre is 1.5 miles) or in Cirencester or Swindon – therefore more driving. It cannot be seen how the proposed development anywhere meets the transport requirements of the NPPF.
Accessibility by Sustainable Modes of Travel (6.0)
As outlined above, walking and cycling from the proposed development will be severely limited due to having to cross and ride along the A417 and it is certain that the development will increase, not reduce, travel and car use.
Accessibility Pedestrian 63 The Planning Application states ‘Coln House School is within 500m’. In reality Coln House School is a Residential Special School, not a primary or secondary school. This demonstrates the lack of knowledge of the applicants. The centre of Fairford (Lloyds Bank) is 1100m from the centre of the proposed development, not 1000m as in the report. The Doctors’ Surgery is 1450m away, certainly not walking distance (preferred maximum for ‘elsewhere’ being 1200m) and the existing parking is already overstretched.
61 Ibid. 5.0 Transport Planning Policy, Minimise journey lengths, para. 5.5, 5.6, p. 9 62 The distances referred to by FPW were measured using a surveyor’s wheel with a start point at the site entrance where it meets the A417 with 150m added, that being a fair measurement to the centre of the proposed development. 63 Curtins Consulting: Transport Assessment, Land off Cirencester Road, Fairford, July 2013, Section 6.0, para. 6.3 Accessibility, para. 6.1-6.11 p. 15-16 The primary school is 2200m and the Secondary School 2350m from the development, not 2000m as in the report: all well over the preferred maximum distances as set out in Table 6.1, p. 15. NB The alternative route to the schools, along Mill Lane, is also dangerous due to its lack of pavement, its winding single carriageway edged by high banks and Cotswold stone walls which allow no refuge from traffic (for cars or pedestrians) and its severely impaired visibility, Cycle64 As outlined above the opportunity for cycling for employment, shopping, schools etc. is very limited given the need to use the busy A417 and/or other congested roads. Some leisure activity could be taken around the local villages on the minor country roads. Public Transport65 Whilst there are, on paper, regular 2 hour services into Cirencester during the day, the timing of the buses does not suit most commuters/shoppers and care has to be taken in choosing convenient out and return times. The comment in 6.22 that there is a connection (74) to Swindon railway station is theoretically correct, but in practice the timetables make connections impractical. The last bus from Swindon is 17.45, which would require commuters to leave London on the 16.45 train – too early to allow a full working day. Usage of public transport is already very low, due largely to the above reasons, and inevitably there will be high numbers of two car families where one or more person is working and mothers are using their cars to take children to school.
Traffic Forecasting (7.0)
Whilst Fairford experiences highest traffic flows at peak hours i.e. 8.00 – 9.00 am and 17.00 – 18.00 pm, the A417 is a major road (effectively a trunk road) and there is heavy traffic throughout the day. Many large commercial vehicles also travel outside the peak hours, often in convoys of two or more, and therefore the flow of trucks and very large agricultural vehicles is constant throughout the day.
In 2007 a Traffic Survey was undertaken by Fairford Forward (a Fairford Town Council initiative) at five positions/junctions on 30th March, 23rd May, 4th June, 15th Nov and 22nd Nov 9th66. This therefore represented a comprehensive survey, covering 5 different dates and resulted in an average, two-way, traffic count of 665 vehicles during the AM peak and 624 vehicles during the PM peak.
In the 2 July 2013 Transport Assessment of the application documents, the road traffic survey (8 May 2013), at the London Road/High Street/Back Lane junction, shows a total of 588 two-way vehicle trips for the AM peak hour and 547 two-way vehicle trips for the PM peak hour (8.11). Whilst it is recognised that traffic flows will vary in time, it is surprising that this indicates a fall, over the 6 year period, of 16% AM peak and 12% PM peak, when Fairford residents have had to put up with increasing traffic flows and delays in the town.
64 Ibid. para. 6.12-6.16, p. 16, 17 65 Ibid. para. 6.17-6.20, p. 17 66 See Appendix 8: Fairford Forward Traffic Survey Figures, p 130 - 140 However, in addition to the proposed Gladman development (3167 estimated vehicles AM peak hour), Fairford now has additional traffic from the recently built Bloor/Linden Homes development (62 estimated vehicles AM peak hour) and in the future from the recently approved Kensington and Edinburgh development east of Fairford and the 22+ homes behind Saxon Way (around 70 estimated vehicles AM peak hour). All these, together with additional traffic from the new developments in Cirencester and Lechlade, will result in considerably more traffic flowing through Fairford and its ‘single file’ road (3m between listed buildings).
A conservative increase in traffic from these new developments is estimated to be over 160 vehicles an hour (AM peak) i.e. between 25 – 30% increase, which is unsustainable given the limitation of the road system and parking problems within Fairford. This increase will also have direct impact on vehicle movements through the surrounding villages.68 It should be noted that the Planning Inspectorate, declared in 2007, ‘the shortfall in visibility on Back Lane and the A417 (in Fairford) is so seriously substandard that the proposal would constitute a danger to highway safety and put vulnerable road users such as cyclists and pedestrians at particular risk’ (Appeal Ref. APP/F1610/A/07/2038227)69.
Highway Impact (8.0)
Table 8.4 This table only shows vehicles travelling straight along the A417 London Street - Bridge Street rather than presenting what is a complicated four-way junction with 3 single file exits/entrances and impaired visibility from 2 exits/entrances. In practice traffic on the A417 at this junction acts in a ‘give and take’ fashion, but often blocks due to vehicles entering from the High Street and due to drivers not respecting the ‘give and take’ convention and/or impeding larger vans/trucks. To gain a true understanding of how this junction will be impacted by traffic generated by the proposed developments, computerised modelling which includes the impact on the Market Square, outside Londis, Milton Street, The Plies junction, the Coronation Street/Horcott Road junction, including parking problems, should be undertaken, since all these locations are problematic.
Conclusion
67 In the survey the developers estimate that the new development will result in 31 extra cars in the morning 2hr peak period and 35 in the evening peak period. The committed developments on Cirencester Rd are shown to result in 67 and 73 traffic movements respectively. The latter is from 171 houses so, if the same ratio of vehicles to houses is taken, the Gladman proposed development of 120 houses should, theoretically, result in 47 (not 31) extra vehicles in the morning peak period and 51 (not 35) in the afternoon peak period. Combined this would result (committed and proposed development) in closer to 1.8 additional vehicles per min, or 110 additional cars an hour (not 90 as quoted). This is forecast for 2013, so will increase even further with time. 68 See Appendix 1, Section 1.3 Transport, p. 41 69 It is appreciated that since this ruling the 2010 Manual for Streets: Wider Application of the Principles has been published in which the visibility requirements for vehicles were reduced, but at this junction vehicles joining the A417 have virtually no visibility of on- coming vehicles until they are actually in the carriageway of the A417.
National Planning Policy Framework 2012 paragraph 32 states that developments can only be refused on highway grounds where the cumulative impact is severe. There can be no doubt, that the impact of this development, when combined with the additional traffic which will be generated by the 2 developments already granted permission and the recently approved other new developments, will be severe on the A417 through the centre of Fairford, not only at the central junction, but at several points on the route where the road is effectively limited to a single carriageway. This will also impact on surrounding villages which are on the routes people will take to work and shopping.
Fairford suffers from extreme traffic congestion, not only due to the A417 reducing to a narrow, single track, at the bottom of the High St (3m between listed buildings) and the 90deg. corner over the Town Bridge, but also the extensive parking on London Road outside the shops/takeaways and on Milton Street and Coronation Street. The number of vans, heavy articulated lorries and very large agricultural vehicles has increased considerably over the past 5 years resulting in ever increasing blockages and danger to other road users, pedestrians and buildings.
Fairford cannot take any more traffic and it is inevitable that the new developments will add considerably to the existing traffic flows, increasing the delays, frustrations and danger, as well as increasing pollution, for new and existing residents alike, and for the drivers of the vehicles passing through the town.
4) Employment
NPPF Achieving Sustainable Development
▪ ‘… to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions. (p.3 para. 8) ▪ Plans and decisions need to take local circumstances into account, so that they respond to different opportunities for achieving sustainable development in different areas. (p. 3 para. 10) ▪ To promote a strong rural economy, local and neighbourhood plans should … promote the retention and development of local services and community facilities in villages such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship. ▪ Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. (p. 9 para. 30)
Sustainable Employment
Homes should be built in sustainable locations. The two most significant factors in deciding whether or not a location is sustainable are a) the existence of work and opportunities for employment and b) the means of transport to that employment which does not involve the use of personal cars. Neither is true for Fairford.
As the town has grown significantly in population, so employment and community facilities have shrunk. Over the past 30 years we have lost numerous shops many which have been converted into homes. Some of the businesses (including premises) which have closed include a building society, market garden, a restaurant, 3 garages/filling stations, the police station, 3 public houses, and a dairy; the buildings have been converted into houses, sometimes several houses70. The Magistrates’ Court building was sold, as was the old primary school site; today the new police station is up for leasing and the post office is in the process of ‘rationalisation’, the outcome of which is as yet unknown. There is no correlation or causality between increase in population and increase in employment as is claimed in the socio-economic report for this application: ‘Bringing new residents to Fairford would help generate additional demand in the local economy and would boost the local labour force.’71 Precisely the opposite has proved to be the case.
Existing opportunities for employment There is limited local work in agriculture, retail and education and leisure constituting the core of employment for local people. In addition there are some small business opportunities of which the largest are the following, providing, at best, fewer than 500 jobs.
70 See Appendix 2 Maps, 2.1 A series of maps showing the development of Fairford, includes information concerning the loss of retail premises, p. 48-52 71 Regeneris Consulting for Gladman Developments, Socio-Economic Impact of New Housing Development, Executive Summary iii, Key Risks and Challenges, p. 2 • Horcott Industrial Estate currently employs a maximum of 178 people at peak times eg. Christmas. Some units are empty but even allowing for a maximum employment level of 10 employees per unit (well above current average) there are a maximum of 270 jobs at this site. • Fairford Railway Station site: New Chapel Electronics employs 72 people; Invertec is relocating north and future plans are unknown. • Godwin Pumps in Quenington ‘employs approximately 120 people and the vast majority of staff live within a 15 mile radius of the site. I do not anticipate any significant change in this number in the near future.’72 • RAF Fairford should also be mentioned. Before 2010 the base was the major employer in the area with 250 civilians, 150 service personnel and various local contractors. Since it was downgraded in Autumn 2010 there are no service personnel but about 200 civilians keeping the base ticking over. There are no plans to reopen the base in the foreseeable future since it is now managed from RAF Croughton and would be serviced from there in an emergency. When there are exercises at the base the population goes up but these are only temporary and relatively infrequent blips.
Emerging Local Plan It is accepted that the emerging local plan for Fairford states, ‘Some further housing will be needed to allow the community to grow sufficiently to help maintain and develop local services and facilities, and to enable affordable housing to be provided.’73 However, this was written before May 2013 and as can be seen from the ‘Recent Developments in Fairford’74 several large-scale planning applications have been approved or have started construction since this time, such that the CDC housing allocation recommendation of up to 260 dwellings between now and 203175 has already been exceeded, even before this application is considered, and the affordable housing requirement has already been met.
Future Employment Regeneris Consultants claim that the site of 120 houses is expected to provide 1 long- term (excluding construction) new job for Fairford and 7 or 8 in the CDC area.76 The development is also expected to sustain 10-15 jobs in local services in the whole Cotswold District area.77
72 Email from Managing Director of Godwin Pumps, Appendix 1: Letters and Emails, 1.4 Employment, p. 46 73 Cotswold District Council, Emerging Local Plan, Second Issues and Options, 6.27, quoted by Regeneris Consulting for Gladman Developments, Socio-Economic Impact of New Housing, Proposed Development in Context, 2.11 p. 12 74 See Introduction to this paper 75 Cotswold District Council, Emerging Local Plan, Preferred Development Strategy May 2013, 6.6.7 Fairford, 6.70. ‘Given the high number of outstanding commitments - and taking account of environmental constraints – up to 260 dwellings are proposed over the period April 2011 to April 2031, including housing built to date and outstanding permissions.’ 76 Regeneris Consulting for Gladman Developments, Socio-Economic Impact of New Housing, Employment Impacts, Household Expenditure Impacts, 4.5 p. 16 77 Ibid, 4.7, p. 17
Given that the proposed development is expected to generate 230 economically active working age residents (those in work or actively seeking work)78, and given that such employment as currently exists in Fairford is already fully staffed, that leaves 215 residents without work in the local area. This would be in addition to the extra estimated pro rata 306 economically active working age residents which will be generated by the 170 houses already under construction on the north side of the Cirencester Road. It is clear from these figures that the majority of residents of the proposed development would have to travel some distance to find work, especially since even such jobs as are generated would be within the Cotswold District rather than in Fairford itself.
Sustainable Travel to Work (see also Section 2, Transport) ‘A key element of national and local transport policy is to ensure that developments are located in areas where alternative modes of transport are available. It is important to ensure that developments are not isolated but are located close to complementary land uses. This supports the aims of integrating planning and transport, providing more sustainable transport choices, and reducing overall travel and car use.’79 This proposal would constitute an isolated development and, in spite of the 13 paragraphs of the Transport Assessment devoted to walking and cycling, there can be no doubt that the vast majority of travel to and from this site will be by car. Public transport is given 3 paragraphs and a couple of tables which carefully leave out any bus timings, and concludes that the site is ‘accessible by public transport.’80 This is true, but does not also mean that it is possible to reach nearby towns in time for work. Cirencester is possible: Fairford 07.40 - Cirencester 08.24 Cirencester 18.00 - Fairford 18.41 Swindon is possible but difficult, especially bearing in mind the fact that Swindon is essentially a series of hubs so arrival at the bus station would be unlikely to be the end of the journey and another bus would be required and the return buses are rather early. Fairford 06.55 – Swindon 07.38 Fairford 07.10 – change in Lechlade – Swindon 08.35 Swindon 16.45 – Fairford 17.40 Swindon17.45 last bus – change in Lechlade – Fairford 18.35
78 Ibid, Executive Summary, Summary of Impacts, Impact Diagram, p. 2 79 Curtins Consulting on behalf of Gladman Developments, Transport Assessment, July 2013, Accessibility by Sustainable Modes of Travel, 6.1, p. 15 80 Ibid, 6.23, p. 18 Gloucester, Cheltenham, Stroud, Kemble, Quenington, Oxford, London – all impossible for a full working day. This situation is recognized in the Emerging Local Plan which accepts that sustainable travel for Fairfordians is ‘Very Limited’.81
Unsustainable Travel to Work Most indicators show that by far the most used method of travel to work is by car and in most households, with 2 working adults and children82, there are likely to be 2 cars used daily. CDC concede that ‘The area as a whole has a self containment level of 42%, which is below average. This indicates that more people than average travel out of the Ward to work.’ The 2011 Census information (figure below) shows that car use is overwhelmingly the most popular method of transport at over 60%, and if you remove walking (which is probably popular in many of the larger towns included here, such as Cirencester) car use represents far more of all commute journeys.83 The low statistic of 2.6% using bus or train is well below the national average of 16% using public transport.84 This is far from a solution ‘which support[s] reductions in greenhouse gas emissions and reduce[s] congestion.’
81 Cotswold District Council, Emerging Local Plan, Role and Functions of Settlement Study 7.15 82 Regeneris Consulting for Gladman Developments, Socio-Economic Impact of New Housing, Executive Summary, Significance of Impacts, iv p. 3. ‘The proposed development of 120 homes with an emphasis on family housing would help to attract a working age population estimated at 220-230 residents.’ 83 Ashburn Planning submission on behalf of Fairford Town Council to the Planning Inspectorate quote a figure of car use for Fairford of 68.6% from the 2011 Census. 84 ONS, 2011 Census Analysis – Method of Travel to Work Analysis for England and Wales, February 2013, England and Wales picture of methods of travel to work in 2011, Figure 1.
Conclusion
Much has been made of the advantages of this development to the local economy but, in truth, the proposal will result in precisely that outcome which is predicted in both the Emerging Local Plan85 and in the Regeneris document: ‘There is a recognized danger of the district becoming a commuter dormitory settlement.’86 How could it be otherwise when local employment opportunities are so few, public transport is so poor and the pull of neighbouring major towns is so great? In spite of the extra residents, the local economy can benefit only marginally as once in the larger towns, most will complete their shopping there, bringing it home in their cars at the end of the day. Older residents, so denigrated as having an adverse effect on the long term sustainability of the town with their lower incomes87, are, in fact, the one group which is most likely to shop locally and the one group which is least likely to inhabit any of the houses proposed.
85 Cotswold District Council, Emerging Local Plan, Role and Functions of Settlement Plan, 7.15. Fairford’s ‘employment role is in danger of decreasing as it has an imbalance in terms of more workers than jobs.’ 86 Regeneris Consulting for Gladman Developments, Socio-Economic Impact of New Housing, Executive Summary, Significance of Impacts iv Table, p. 3. 87 Ibid Conclusion
Over the years, Fairford has accepted growth, at times quite significant growth, with equanimity. Valuable land has been sold off in the centre of the town (police station, Magistrates’ Court, primary school) to be replaced by expensive housing. The schools are all now on the edge of the town, facilities have been permanently lost (we have just lost our police station for a second time in spite of assurances that this would not happen) and gradually we are becoming a dormitory for the large towns which are within relatively easy commuting distance.
In the meantime, the local authorities and statutory bodies have neglected the infrastructure of the town. We are just outside the AONB, at the edge of the county, and lately seem to have become a convenient location for large developments. In recent years planning applications have been granted for holiday homes stretching along the length of the A417 between Fairford and Lechlade and the latest development of 170 houses, already being built, is by far the largest we have had to cope with. Communities need time to absorb new residents if they are to thrive and remain ‘communities’, a fact acknowledged in the emerging local plan which states that, ‘The latest assessment of potential housing land, from the SHLAA (Strategic Housing Land Availability Assessment), for Fairford suggests that as many as 900 dwellings could be delivered within the Plan period. Clearly, nothing like that scale of development would be appropriate over the next 20 years … Given the high number of outstanding commitments - and taking account of environmental constraints – up to 260 dwellings are proposed over the period April 2011 to April 2031, including housing built to date and outstanding permissions.’ In spite of these CDC reservations, well over 300 houses are approved and already in the pipeline - and it is only 2014.
It is a central tenet of the NPPF that development must be sustainable and it is clear that the current situation is not tenable. The sewers throughout the town need urgent and extensive investment, far in excess of any contribution developers might be expected to make; the mains water supply is overstretched; employment opportunities in the town are reducing rather than increasing (simply adding yet more residents will not halt this process); schools are overfull; the surgery has limited capacity for expansion and the A417 through the centre of this old town can never be brought up to the standard expected of such a major route. The problems, particularly concerning the road, flooding, water mains and foul water drainage, are long standing and persistent; on the whole, they remain unresolved - the EA flood alleviation for some of the town, being a notable exception. The recent explosion in applications for large-scale developments has brought the situation to a head, and the constant pressure on the CDC from developers has given the community the sense that their legitimate concerns are being overridden and ignored.
In addition we stand to lose the last remaining fragment of a rural entry into the town along the main road. Much care has been taken to enhance this aspect of the town with wide, tree-lined verges heavily planted with daffodils, bordered by Cotswold stone walls, leading, on the south side (the side of this application), to old Cotswold stone buildings. The northern edge is now lined with new, volume built homes. Please leave unspoilt the last vestige of open, rural views. And it is not just the view from the road which could be destroyed, but the lovely old footpath which runs down the far side of the field from the Burdocks would be quite ruined.
On all these grounds, therefore, we request that you refuse this appeal, and send a message to CDC that they must take account of the needs of Fairford and understand that it is a historic market town worth protecting. This is an unsustainable location for large-scale developments until such time as the issues arising from inadequate infrastructure have been fully addressed rather than being consigned to the mists of Grampian conditions.