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Response to JSP Technical Evidence Work Consultation

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Response to JSP Technical Evidence Work Consultation Clerk: Mr James Carpenter, Whitegates, Sundayshill Lane, FALFIELD Falfield, Wotton under Edge PARISH COUNCIL Glos. GL12 (07484 102588) [email protected] www.falfieldparishcouncil.org.uk West of England Joint Spatial Plan Date: 6th January 2019 Falfield Parish Council represents a small rural parish in the north of the WECA region. Two thirds of the Buckover SDL is being proposed within our parish boundary with the remainder within the Thornbury boundary. Most of our comments therefore relate to the Buckover SDL but we have also flagged up some relevant to the Charfield and Thornbury SDL’s. We have already commented extensively via earlier consultations and trust that our previous comments are passed onto the Government Inspectors rather than repeat the same observations again here. We wish to express our unhappiness with this West of England Joint Spatial Plan: November 2018 JSP Technical Evidence Work consultation process. As mentioned before these, 6 to 8 week public consultation periods are not long enough to consider this quantity and complexity of documents. The timing of this consultation, held yet again over the Christmas period, is both inconvenient to the consultees, and disrespectful of the time given by so many volunteers to respond. Our residents deserve better consideration, given that there are many existing residents of our parish who will be significantly and adversely affected by these strategic proposals. The time given for the public to consider such a large number of pages – for example 834 pages in just one of the documents is woefully insufficient. By comparison a current South Gloucestershire consultation on the removal of recycling bags comprising of just twelve pages is given a longer consultation period of 12 weeks. Some of the documents, offered only in electronic format are unwieldy and not user friendly to navigate, particularly for lay people. The format, indexing and page numbering is inconsistent and there is a lack of logical structure. There is also over repetition of the same paragraphs again and again, with the same words simply cut and pasted repeatedly to ‘pad it out’. Long term it is not a good collection of documents for WECA to move forwards with. Nevertheless Falfield Parish Council aim to respond to this consultation in a structured and meaningful way. Comment on Schedule of Proposed Changes to wording There is an error in the reference system in WED 002 for instance PC15 states Policy 7.9 Buckover whereas Buckover is actually Policy 7.8. P a g e 1 | 15 Falfield Parish Council amongst others have previously asked for more assurance on the timing of delivery of infrastructure in relation to delivery of housing and other development, preferring infrastructure first. We note that this has been included for some of the SDL’s policies 7.1 – 7.12 but has not been adequately set out for the Buckover SDL. The WED004H 7.8 Buckover SDL requires similar wording. For example in PC05 page 34 it says ‘No dwellings will be completed at the Whitchurch SDL ahead of: i Park & Ride, and ii the multi-modal link A4-A37-south Bristol link ‘, whereas for Buckover it merely says ‘Provision of a strategic transport package including as appropriate delivery of or contributions towards:’1 Where is the assurance these measures will be provided ahead of the development? We expand on this request together with further reasoning under the Transportation & new Infrastructure heading below. Consideration of alternative locations for development We do not feel that this consultation adequately responds to the Inspectors request for further analysis of alternative locations with an open mind. The use of scoring indexes is a rigid way of comparison and can be easily manipulated by the headings selected and the traffic light weighting given to each. Even after this, the selection of preferred sites from this data is spurious. We would have preferred to see more use of strategic diagrams and creative exploration of alternative approaches on alternative sites across the WECA region, which we believe is what was actually being asked for. The inspectors question is yet to be adequately answered in our opinion. Key points The consultation appraisals raise valid points, some of which have yet to be addressed in the strategy as submitted and still require further consideration. We expand on each of the key points listed below further in this response and include our cross references at the end. The remoteness of the Buckover SDL makes daily travel for the affordable housing unaffordable. The Buckover SDL does not contribute to promoting the conservation and wise use of land. The Buckover SDL destroys some of the region’s best agricultural land. The Buckover SDL is to the detriment of high sensitivity landscape. The Buckover SDL destroys part of the region’s strategic green infrastructure The Strategic Green Gap between Thornbury and Buckover is under the control of others The Buckover SDL site and downstream is at risk of surface water flooding The Buckover SDL site has ecological constraints. There are risks that Buckover SDL site will affect the Severn Estuary SAC, SPA Ramsar habitats. The Recommendations from WECA’s own habitat assessments and any mitigation measures put forward are yet to be added to the Buckover SDL policy wording. P a g e 2 | 15 At Buckover SDL sufficient sewage treatment capacity must be put in place ahead of all new development. Measures to deal with the existing electricity pylons crossing the Buckover SDL requires inclusion. Consideration of mains services connection opportunities for existing residents to be added The negative effects of new housing development in close proximity to a scheduled nuclear reactor site needs to be given weight. The Buckover SDL does not benefit greenhouse gas emissions There is potential for areas of poor air quality along the A38 and near to M5 Road noise pollution at the Buckover SDL will be detrimental to residents well being The Buckover SDL will compromise the ability of the A38 to act as an effective relief road to the M5. All major healthcare facilities are outside of reasonable distance of the Buckover SDL. Infrastructure need to support housing and requires timely provision of transport and utilities The M5 J14 works completion exception in relation to housing delivery is not acceptable. The Buckover SDL is predicted to only have limited access to substantial services and facilities Statistics provided imply that Bristol centric public transport measures are not relevant to half of the South Gloucestershire population. The Metrobus serving the Buckover SDL only offers public transport on a single linear route. Most Falfield parishioners will not benefit, they remain unconnected by the public transport measures. Mitigation for increased vehicle flows on the A38 between Buckover and Falfield has been overlooked. Why is a Buckover ring road still not being considered as an option? The Buckover SDL does not have good non-private car connections to Charfield rail station. Despite all the mitigations offered, the traffic situation is predicted to get worse after 2026. It is essential that the Buckover, Thornbury and Charfield SDL’s have all of their programmed strategic infrastructure measures securely in place and completed before housing and other development commences. P a g e 3 | 15 The remoteness of the Buckover SDL makes daily travel for the affordable housing unaffordable. The aspirations regarding affordable housing2 are commendable but planning to locate large quantities of it in a remote location in the far northern corner of the WECA region is questionable. It is not cheap to travel long distances to employment, services and facilities; it is also time consuming. The Transport Topic Paper admits that people are unwilling to travel far to lower paid jobs. Dependence on bus use to connect to places, as there is so little choice of services within walking distance, is difficult if a resident cannot afford the bus or rail fares – It is currently for a return journey it is approx. £24.00 for a family of four (two adults, two children) for a trip from Thornbury into Bristol city centre. A single train return journey from the closest station to Falfield to Bristol Temple Meads for the same family of four would cost approx. £25.80 but this would require using other means of transport to get to and from each station. Unless infrastructure is in place first those most in need will be isolated. Being offered only one Metrobus route to expensive city centre shops, strictly limits customer choice and is not ideal. We stress that Infrastructure must be in place before housing and other development commences. The Buckover SDL does not contribute to promoting the conservation and wise use of land. Falfield Parish Council agrees with the conclusion reached under Sustainability objective 4d that the Buckover SDL does not contribute to promoting the conservation and wise use of land.3 The Buckover SDL destroys some of the region’s best agricultural land. Surely the statements ‘local food production is given emphasis within the new settlement’ and ‘Local food production is a key garden community principle’ 4 are included for irony in the justification for the location of Buckover Garden Village. This development proposes the loss of some of the South West regions best and most versatile arable farmland! Table 3.3 Topic5 refers to Agricultural Land Classification and the smaller area of the best Grade 1 and 2 land across the JSP area. It concludes ‘Without a co-ordinated strategic approach to development and infrastructure (as contained in the JSP), development within areas of higher grade agricultural land is likely to occur, damaging the sub-region’s agricultural land supply.’ However the JSP does not heed its own advice in relation to the Buckover site.
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