Stroud Town Centre Neighbourhood Development Plan

Summary of the representations submitted to the Independent Examiner

Representation 1

From: Jackie Longworth ***Redacted*** Sent: 03 January 2016 13:53 To: Rios, Ricardo Cc: _WEB_NDP Consultation Subject: RE: Stroud Town Centre Neighbourhood Development Plan - Shaping the Heart of Stroud - Notification under Regulation 16 of the Neighbourhood Planning (General) Regulations 2012 (As Amended) and the Localism Act 2011

Thank you for the invitation to participate in the above consultation.

Fair Play South West would ask whether the Development Plan has been subject to equality impact assessment, in particular a gender impact assessment? In our experience economic development provides a unique opportunity to reduce the economic disadvantage of women relative to men. For example, the gender pay gap is caused in part by the inaccessibility of well paid jobs to those with caring responsibilities. Careful planning of the location of good employment opportunities and local public transport can go some way to ameliorate this; also working with employers to offer well paid jobs with flexible hours and part time working.

We would also ask which local women’s groups have been consulted in the development of your plans?

I hope these comments are helpful? Yours Sincerely,

Dr Jackie Longworth Chair, Fair Play South West

***Redacted***

Representation 2

From: Stuart, David [mailto:[email protected]] Sent: 08 February 2016 16:41 To: Rios, Ricardo; _WEB_NDP Consultation Subject: Stroud Town Centre Neighbourhood Development Plan - Shaping the Heart of Stroud - Notification under Regulation 16 of the Neighbourhood Planning (General) Regulations 2012 (As Amended) and the Localism Act 2011

Dear Ricardo

Many thanks for this consultation, and apologies for not responding before now.

But as it happens, there is nothing we would wish to comment on other than to strongly congratulate the Stroud community on the scope and depth of their Plan.

We made a couple of observations in response to the consultation draft and are pleased to note that these appear to have been accommodated (cc’d to you at the time but attached again now for information). From a heritage perspective this is certainly the most comprehensive and informed Plan we have yet to see in the south west.

Hopefully the Plan will have a smooth ride through to being made. It will then be interesting to monitor how the Plan addresses identified issues and shapes the area through its application.

Kind regards

David Stuart | Historic Places Adviser South West Direct Line: 0117 975 0680 | Mobile: 0797 924 0316

Historic England | 29 Queen Square | Bristol | BS1 4ND

We have launched four new, paid-for Enhanced Advisory Services, providing enhancements to our existing free planning and listing services. For more information on the new Enhanced Advisory Services as well as our free services go to our website: HistoricEngland.org.uk/EAS

Representation 3

From: Gibson Guy [mailto:[email protected]] Sent: 04 February 2016 15:49 To: _WEB_NDP Consultation Subject: Draft Stroud Town Centre Neighbourhood Development Plan

Dear Mr Rios,

Thank you for inviting Network Rail to comment on the draft Stroud Town Centre Neighbourhood Development Plan. Having read the document I note that two policies in particular relate to land in Network Rail ownership – Policies Policy ZP3 and ZP4a. The principal objectives of these polices are set out below:

Policy ZP3

 Creation of pedestrian bridge across railway.  Redesign upgrade of station forecourt.  Re-use and/or redevelopment of unused railway land.  Creation of more attractive public space between listed Brunel Goods Shed and Brunel Mall mulita-storey car park.  Creation of new pedestrian link between London Road and Brunel Goods Shed.  On south side of railway development of car park for mixed uses including residential.  Making visual improvements to Rowcroft Railway bridge.

Policy ZP4a – Railway arches site

 Re-opening of railway arches.

In principle Network Rail do not object to any of the above policy objectives and appreciate that these alterations would have potential to enhance the townscape, improve connectivity and make better use of surrounding land. However, Network Rail do have concerns regarding the availability of funding to carry out these various schemes. In respect of constructing a new pedestrian bridge over the railway the cost estimate for this work as set out in Appendix 7 does appear very low.

Land identified on the south side of the railway station for a mixed use development is currently used for station car parking. Therefore development of this land without finding an alternative and suitable parking area would leave the station short of operational parking. It is anticipated that the Train Operating Company (First Great Western) that currently lease and run the station would be opposed to this loss of parking. Possibly the construction of a multi-storey car park on part of this site could free up land for the mixed use development proposed, however, the cost of constructing such a parking facility would need to be borne by the development and this may have implications on the nature and overall viability of the project.

It is understood that the feasibility of bringing the railway arches back into use was looked into a few years ago by Network Rail but it was concluded the likely rental incomes would not be sufficient to cover the cost of the work required. If the surrounding area is improved as proposed in the NDP then this may have a positive impact on rental values but the viability of this proposal would require careful consideration.

Clearly, in order for the above policy proposals to progress further work is required on the layout, design, costings and overall viability of each proposal. As a principal land owner Network Rail ask that they be involved in this process. This process should also include and take into account the views of First Great Western as station operator and also the current leasee of the Brunel Goods Shed. In addition to the above site specific comments I would also be grateful if the council could take into account the following more general comments in the preparation of this NDP:

Network Rail owns, operates, maintains and develops the main rail network. This includes the railway tracks, stations, signalling systems, bridges, tunnels, level crossings and viaducts. The preparation of development plan and transport policy is important in relation to the protection and enhancement of Network Rail’s infrastructure. It is considered that NR’s involvement in the production of this document will be to ensure that rail infrastructure continues to meet the needs of the areas communities and that there is an acceptable delivery mechanism in place to meet this commitment. Councils must continue to engage with Network Rails Network Planning and Strategy teams in order to identify future requirements. In this context NR would hope that the DPD would address the following:

Level Crossing Safety

Development proposals’ affecting the safety of level crossings is an extremely important consideration for emerging planning policy to address. The impact from future development can result in a significant increase in the vehicular and/or pedestrian traffic utilising a crossing which in turn impacts upon safety and service provision.

As a result of increased patronage, Network Rail could be forced to reduce train line speed in direct correlation to the increase in vehicular and pedestrian traffic using a crossing. This would have severe consequences for the timetabling of trains and would also effectively frustrate any future train service improvements. This would be in direct conflict with strategic and government aims of improving rail services. Therefore the location of proposed new development is an important consideration for Network Rail and should form part of any initial appraisal of future development sites.

Protection Assets

Network Rail (in line with normal practice) would expect to be consulted on any development that may impact on their assets in the area. In this regard the imposition of appropriate planning conditions are likely to be an important tool that will enable planning permissions to be granted whilst also safeguarding NR assets.

Future Funding

Network Rail is a publicly funded organisation with a regulated remit. It is not be reasonable to require Network Rail to fund rail improvements necessitated by commercial development. It is therefore appropriate to require developer contributions to fund such improvements.

The likely impact and level of improvements required will be specific to each station and each development meaning standard charges and formulae may not be appropriate. Therefore in order to fully assess the potential impacts, and the level of developer contribution required, it is essential that where a Transport Assessment is submitted in support of a planning application that this quantifies in detail the likely impact on the rail network.

To ensure that developer contributions can deliver appropriate improvements to the rail network we would recommend that Developer Contributions should include provisions for rail.

We therefore ask the council to consider the following:

. A requirement for development contributions to deliver improvements to the rail network where appropriate. . A requirement for Transport Assessments to take cognisance of impacts to existing rail infrastructure to allow any necessary developer contributions towards rail to be calculated. . A commitment to consult Network Rail where development may impact on the rail network and may require rail infrastructure improvements. In order to be reasonable these improvements would be restricted to a local level and would be necessary to make the development acceptable. We would not seek contributions towards major enhancement projects which are already programmed as part of Network Rail’s remit.

Kind Regards

Guy Gibson Town Planner - Property Network Rail 1st Floor, Temple Point, Redcliffe Way, Bristol, BS1 6NL

M 07710 961616 E [email protected] www.networkrail.co.uk/property

Representation 4

From: Rachel Russell ***Redacted*** Sent: 11 January 2016 21:09 To: _WEB_NDP Consultation Subject: Stroud Town Centre Neighbourhood Development Plan 2015-31 Shaping the Heart of Stroud submission draft: Comments

Policy ZP3

I object to the following part of the policy ZP3: “South side: • Development of the car parks on the south side of the railway for mixed uses, including residential, subject to the retention of the overall level of car parking spaces serving the town centre.”

The car parks on the south side of the railway are needed to ensure the station is useable by commuters, shoppers and other visitors traveling to and from Stroud. It is extremely valuable to Stroud's economic, social and cultural life to have good provision of parking close to the station; therefore the caveat in this part of the policy that development of the car parks is acceptable subject to the retention of the overall level of parking spaces serving the town centre does not make proposing the area as a potential development site justifiable.

This part of Policy ZP3 therefore seems to be contrary to some of the themes and objectives of the draft Stroud Town Centre Neighbourhood Development Plan (NDP) such as “sustaining the economy of the town centre”, “improving access to the town centre” and “strengthening the social and cultural fabric of the town centre”.

Apart from this objection, I think the draft Stroud Town Centre NDP is a well drafted planning document which responds to issues raised during public consultation and has the potential to improve life in Stroud town centre over the next 20 years.

Rachel Russell 9 Vatch View, GL5 1JW

Representation 5

From: Zoe Hughes [mailto:[email protected]] Sent: 05 January 2016 12:42 To: _WEB_NDP Consultation Subject: Stroud Town Centre Neighbourhood Plan

Thank you for consulting Sport England on the above Neighbourhood Consultation.

Planning Policy in the National Planning Policy Framework identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Encouraging communities to become more physically active through walking, cycling, informal recreation and formal sport plays an important part in this process and providing enough sports facilities of the right quality and type and in the right places is vital to achieving this aim. This means positive planning for sport, protection from unnecessary loss of sports facilities and an integrated approach to providing new housing and employment land and community facilities provision is important.

It is important therefore that the Neighbourhood Plan reflects national policy for sport as set out in the above document with particular reference to Pars 73 and 74 to ensure proposals comply with National Planning Policy. It is also important to be aware of Sport England’s role in protecting playing fields and the presumption against the loss of playing fields (see link below), as set out in our national guide, ‘A Sporting Future for the Playing Fields of England – Planning Policy Statement’. http://www.sportengland.org/facilities-planning/planning-for-sport/development- management/planning-applications/playing-field-land/

Sport England provides guidance on developing policy for sport and further information can be found following the link below: http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/

Sport England works with Local Authorities to ensure Local Plan policy is underpinned by robust and up to date assessments and strategies for indoor and outdoor sports delivery. If local authorities have prepared a Playing Pitch Strategy or other indoor/outdoor sports strategy it will be important that the Neighbourhood Plan reflects the recommendations set out in that document and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support the delivery of those recommendations. http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and- guidance/

If new sports facilities are being proposed Sport England recommend you ensure such facilities are fit for purpose and designed in accordance with our design guidance notes. http://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/

If you need any further advice please do not hesitate to contact Sport England using the contact details below.

Yours sincerely

Planning Administration Team [email protected]

Zoe Hughes Senior Planning Administrator T: 02072731761 M: 07919994793 F: 01509 233 192 E: [email protected]

Representation 6

Name (required) Jill Fallows, Property Manager, Stroud District Council Email address [email protected] Phone number 01453-754433 Postal address Ebley Mill, Ebley Wharf, Stroud, Glos Post Code (required) GL5 4UB Paragraph or Comments or suggested changes policy number Policy ZP3 Object: There is no public access between the Brunel Mall multi- Railway storey car park and the Goods Shed. The car park is closed during Land/Cheapsi evenings and weekends to limit anti-social behaviour. Any proposals de Car Parks to create a public link would need to prove that the management and pg 63 use of the car park was not prejudiced, that there was sufficient funding for the additional management costs and that opening hours were acceptable. The plan on page 63 still shows a positive red arrow for pedestrian links between the car park and Brunel Goods shed and the car park and London Road.

Policy AP5a, Object: Policy is absolutely restrictive and prevents any Local Green development which may be appropriate. Capel’s Mills is owned by Spaces Pg 40 the District Council and Wallbridge is due to be transferred to the District Council. Both are key sites for canal uses and the wider public benefit from this ownership requires having the ability to change to these uses where, and if ever, appropriate. SDC objects to this designation. Policy AP10, Buildings of Cultural Object: The Subscription Rooms and the Old Town Hall are owned Importance pg by the District Council. The District Council is responsible for the 46 control, use and management and safeguarding the local public interest. The wider public benefit from this ownership requires having the ability to change to these uses where, and if ever, appropriate.

Policy ZP1c, Change AP10 “…will be safeguarded for public enjoyment and Important community use where aligned line with the owners’ aims and Town Spaces strategies” pg 55 Object: The Subscription Rooms Forecourt and the Shambles are owned by the District Council. The District Council is responsible for the control, use and management and safeguarding the local public interest. The wider public benefit from this ownership requires having the ability to change to these uses where, and if ever, appropriate. Section D para 4.1.5 pg Change ZP1c “The following important town spaces will be 80 safeguarded for public enjoyment and community use and enhanced where aligned line with the owners’ aims and strategies”

Object: The Plan should not conflict with other authorities’ policies to ensure coherent development. Delete “serious”

The Local Plan is now adopted and there is no submitted draft.