Clerk: Mr James Carpenter, Whitegates, Sundayshill Lane, FALFIELD Falfield, Wotton under Edge COUNCIL Glos. GL12 (07484 102588) [email protected] www.falfieldparishcouncil.org.uk

West of 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 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 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.

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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 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.

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 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 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.

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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.

Falfield Parish Council agree that the Buckover SDL performs badly under Sustainability objective 4e and item 5.586 regarding the significant loss of productive, best and most versatile agricultural land. A large part of the Buckover site is Grade 2 designated land and is recorded as some of the best agricultural land in the South West of England. The mitigation offered of avoiding identified areas of the best and most versatile (high grade) agricultural land (land in grades 1, 2 and 3a) is totally at odds with the proposed Buckover location plan. The loss of this prime land cannot be mitigated.

The Agricultural land classification map on page 119 of the Consolidated Sustainability Appraisal Appendices, is of poor quality, please find attached a clearer version on page 14 illustrating the limited amount of Grade 2 land in the region and the large amount of high grade land being lost to the Buckover SDL.

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We do not agree that the loss of this prime agricultural land can be offset against other sites and given a partially positive outcome rating for the purposes of the rating index as on page 714 of the Sustainability Appraisal.7

The Buckover SDL is to the detriment of high sensitivity landscape. We challenge the statement that the land is relatively unconstrained by high landscape value in the audit trail of the SDL options.8 This is totally misleading and contradicted elsewhere. In WECA’s own Sustainability Appraisal highlights3 it states there is ‘some landscape value on slopes to south and east of the locality.’ And in Sustainability objective 4c3 it comments ‘Buckover is located in the Falfield Vale landscape character area and including the side slopes of the Severn Ridge at which overlook the area from the south. The bowl shaped landscape is overlooked from the higher ground to the north where the medieval deer park of Eastwood Park has a parkland character. The landscape in this area is considered to be of high and medium to high sensitivity.’ No mitigation or enhancement is being offered for the loss of this beautiful part of our local landscape.

Aerial picture looking north towards the medieval deer park of Eastwood Park from Buckover

The Buckover SDL destroys part of the region’s strategic green infrastructure The importance of areas of strategic green infrastructure is briefly mentioned on pages 106 to 108 of the Consolidated Sustainability Appraisal appendices. A poor quality plan diagram is included. Please find on page 6 a clearer version demonstrating that the Buckover SDL proposal is in conflict with this strategy and obliterates part of it.

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The Strategic Green Gap between Thornbury and Buckover is under the control of others We flag up that under sustainability Objective 1a the green strategic gap3 proposed between Thornbury and Buckover SDL is land not within the ownership of the developer promoter of Buckover or the Council. Despite their stated intentions, the management and appearance of this proposed key green landscape edge is out of their control.

The Buckover SDL site and downstream is at risk of surface water flooding Many of our parishioners have expressed concerns about surface water flooding around the Buckover site. They suffer from the effects of heavy clay ground and extremely high water tables every year, there are many underground springs. We concur that Buckover is at risk of surface water flooding as flagged up in sustainability objective 4G.3

Item 5.20 states ‘The resultant loss of Greenfield land in the West of England will also mean that some high grade agricultural land may be lost and areas of impermeable surfaces across the plan area are likely to rise and as such minor negative effects have also been identified in relation to 4e: best and most versatile agricultural land, 4f: tidal/fluvial flooding and SA objective 4g: surface water flooding over the medium and long term.’9 We do not agree that this can be rated as a minor effect; this is a significant negative effect.

The Buckover SDL site has ecological constraints. We dispute the statement in Sustainability Appraisal Policy 7.8 Buckover3 that there are ‘No known significant ecological constraints.’ at Buckover. This is misleading. Item 5.60 states that Buckover contains or is in ‘close proximity to biodiversity features’.10 Adverse ecological impacts related to this site are also flagged up under the updated Habitats Regulations Assessment. Information is available from South Gloucestershire Council on the Biodiversity Action Plan within the parish of Falfield detailing species of principle importance. We also know that there is also evidence that other protected species reside within the site perimeter, these include, Adders, Grass-snakes, Stag Beetles, P a g e 6 | 15

dormice, a wide variety of bat species, hedgehogs, owls, albino fallow deer and Greater Crested newts. Ecological assets such as the Ridgewood SNCI are also identified in Sustainability objective 4b.3

At the Nailsea SDL, consideration has been given to safeguarding and enhancing local species i.e. ‘Strategic approach to the assessment, safeguarding and enhancement of greater and lesser horseshoe bat habitat, and Tickenham; Nailsea and Kenn Moor SSSI interests. This includes investigating the potential for a dark corridor through the new development linking habitats at Backwell through to open countryside to the north and at Batch Farm Meadow wildlife site.’11 The WED004H 7.8 Buckover SDL requires similar wording included for all its protected species.

There are risks that Buckover SDL site will affect the Severn Estuary SAC, SPA Ramsar habitats. A substantial part of the Buckover site is within the Severn Estuary SAC, SPA Ramsar buffer zone.12 At Buckover significant effects from air pollution of the Severn Estuary European site are flagged up as part of the submitted assessment. Meanwhile it also raises uncertainty whether there will be a significant effect from both recreational pressure and for water quality/quantity. It states that further consideration of air pollution, recreational pressure and water quality/quantity is required as part of the Appropriate Assessment stage of the HRA. This needs to be added to the site policy 7.8.13

The ‘Summary of appropriate assessment conclusions for the Severn Estuary SAC, SPA and Ramsar’14 reiterates these points flagged up in the screening regarding air pollution,15 recreational pressure16 and water quality.17 However Falfield Parish Council is not convinced by the repeated use of the term ’uncertain’ in the short conclusions reached and it is clear that more study needs to be done in relation to the impacts of the Buckover site to ascertain whether or not it is an appropriate location for development.

The Recommendations from WECA’s own habitat assessments and any mitigation measures put forward are yet to be added to the WED004H 7.8 Buckover SDL policy wording. Further consideration and a cost allowance for the effects of air pollution affecting habitats, the effects of recreational pressure affecting habitats, the impacts on water quality/quantity affecting habitats is still required.13

At Buckover SDL sufficient sewage treatment capacity must be put in place ahead of all new development. The ‘Summary of appropriate assessment conclusions for the Severn Estuary SAC, SPA and Ramsar’14 also flags up the issue of development within the JSP placing pressure on existing sewage treatment capacity. There are no existing mains sewers in the vicinity of the Buckover site. It recommends that that sufficient sewage treatment capacity is put in place ahead of new development proposed in the JSP to avoid adverse effects on the integrity of the SAC from changes in water quality. Oddly sewage treatment is not mention in the WED004H 7.8 Buckover SDL policy, and it needs to be added as an essential piece of prior infrastructure before commencement of the development and the long lead in times for Wessex Water to deliver it factored in to programmes.

Measures to deal with the existing electricity pylons crossing the Buckover SDL requires inclusion. There are existing large electricity pylons crossing the Buckover SDL. At the Nailsea SDL consideration has been given to burying the cables as part of the essential prior infrastructure policies i.e.

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‘Consideration of relocation/undergrounding of existing overhead power lines’.18 The WED004H 7.8 Buckover SDL requires similar wording. This also needs an infrastructure cost allocation.

Consideration of mains services connection opportunities for existing residents Wording also needs to be added to the WED004H 7.8 Buckover SDL to enable consideration of allowing existing residents the opportunity to connect to new mains services infrastructure e.g. mains sewers, gas etc. There is no mains gas in the parish at present and mains sewers only serve some houses near the prison.

The negative effects of new housing development in close proximity to a scheduled nuclear reactor site needs to be given weight. The proximity of some of the SDL’s to the replacement Oldbury nuclear Power Station site is hinted at19 as a positive but the negative effects has not yet been given any consideration or weight.

Both The Department for Business, Energy & Industrial Strategy and the Office for Nuclear Regulation’s guidance clearly says that power stations should not be sited close to large populations for safety reasons. Following Japan’s awful Fukushima disaster, the ONR called for planning restrictions on new residential and commercial development near nuclear plants.

There are many who question the logic of locating a new community of over 8000 people at Buckover within sight of and downwind of the preferred site for the new Oldbury nuclear power station. There are serious health and safety and emergency evacuation implications to be considered. It’s unlikely, but In the event of a major catastrophe the air could be unsafe to breathe within an evacuation zone radius of ten miles.

Why is WECA overlooking safety guidance when locating brand new housing settlements at Buckover and Thornbury within just four and a half miles of a scheduled nuclear reactor site?

The Buckover SDL does not benefit greenhouse gas emissions Regarding Sustainability objective 5b3 & 20 Falfield Parish Council does not agree that the Buckover SDL should be positively rated in the objective to reduce non-renewable energy consumption and greenhouse emissions, it should be negatively rated. This is due to the site currently being Greenfield, and the proposal is totally reliant on road travel to connect to major facilities and is located in the furthermost northern corner of the WECA region with maximum travel time to the city centres. Item 5.11921 is also contradictory as it implies that the Buckover development would benefit greenhouse gas emissions in the area when it clearly would be worse than at present.

There is potential for areas of poor air quality along the A38 and near to M5. Sustainability objective 1b3 comments on the potential for areas of poor air quality along the A38 and near to M5. This is a flaw with the Buckover proposal as it is sandwiched between these increasingly congested main roads. Falfield Parish Council does not agree with the SA findings that replacing Greenfield land with any development that depends on road transport can be attributed any positive effect however minor in relation to air quality.22

Road noise pollution at the Buckover SDL will be detrimental to residents well being The baseline information of the Sustainability Appraisal23 states that excessive or persistent noise can have a detrimental effect on health and wellbeing. The main impacts are on raised blood pressure,

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cardiovascular diseases, sleep disturbances, annoyance hearing impairment and tinnitus that affects mental health and cognitive impairment.

Table 3.3 topic c (human health)24 states that ‘without a co-ordinated strategic approach to development and transport infrastructure (as contained in the JSP), noise levels related to traffic are likely to increase along major transport corridors. There is uncertainty over what will happen to neighbourhood noise in the future due to the lack of data.’ However this strategic advice has not been heeded in the actual JSP as it relies on putting more vehicle load from housing and employment use on the major transport corridors due to the remote location of some of the SDL’s and the increase in population.

The Buckover proposal is sandwiched between two heavily used and increasingly congested main roads, i.e. the A38 and the M5 and is ill placed in term of adverse noise impacts. Both are significant noise generators 24 hours a day and existing residents will testify to increasing road noise pollution.

It is concerning that WECA admits that there remains a gap in consistent noise mapping across the West of England area and that they have given little weight to noise pollution in their selection of the SDL sites.

The Buckover SDL will compromise the ability of the A38 to act as an effective relief road to the M5. Sustainability objective 1b3 comments on the requirement to ensure the A38 can continue to act as an effective relief road to the M5 without detriment to the new resident’s health & wellbeing. This should be expanded to include existing residents along the A38 between M5 Junctions 14 and 15. Falfield Parish Council fail to see how introducing 3000 more houses and employment land wholly reliant upon this stretch of the A38 can keep it effective. We are yet to see any proposal which tackles this conundrum. At present when there is a local motorway incident, this part of the county quickly becomes gridlocked, partly because it is hemmed in by the M5, M4 and the and partly because the majority of alternative routes to the A38 are narrow single track rural country lanes.

All major healthcare facilities are outside of reasonable distance of the Buckover SDL. Sustainability objective 1c3 comments that all healthcare facilities are outside of reasonable distance of Buckover. Falfield Parish Council have yet to see any proposals to address this. The JSP fails to connect Buckover with transport provision to where the regions nearest Minor Injuries Unit is located. We are also dismayed to see that the option for a direct Metrobus route from Thornbury to Bristol city centre via and North Horfield which might connect to the nearest major hospital at Southmead has been discarded.25 As the A38 is the emergency relief road for the M5 in the event of a motorway accident the A38 becomes stationary for miles at a time. This will be in the heart of the Buckover development. This creates a significant issue for emergency services. Falfield and Buckover have some of the worst emergency response times in the country with only 25% of red 1 & 2 calls answered within the national SLA. Building another 3000 house in this area puts all of these people at risk with no way of quickly accessing a hospital.

Transportation & new infrastructure Item 4.132 under the heading ‘Reasons for selecting the preferred alternatives and discounting other options’ states ‘many of the areas located beyond the Green Belt have relatively poor travel choices

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and therefore pose challenges in improving travel choices and mitigation of their impacts. Development in ..... Buckover....and Thornbury will increase travel distances and improvements will be required to travel choices from these locations.’26 This is a negative not a reason for selection of these sites.

Falfield Parish Council note the updated requirement for ‘provision of a strategic transport package including as appropriate delivery of or contributions towards: Metrobus Extension to Thornbury & Buckover GV requires provision of a strategic transport package including as appropriate delivery of or contributions towards: Metrobus Extension to Thornbury & Buckover GV, A38(N) Park & Ride, A38 Strategic cycle route, M5 J14 improvements, Charfield Rail Station re-opening, local bus service improvements (including new local shuttlebus to Thornbury), strategic and local cycle and pedestrian connections to Thornbury and other local highway network improvements as necessary.’

 We have concerns regarding the phrase ‘delivery of or contributions towards’ and the ambiguity of who will be ensuring that these requirements will be delivered.

Infrastructure needs to support housing and requires timely provision of transport and utilities  Historically there has been poor coordination of both in the region and we worry that infrastructure implementation will be misaligned with local growth in terms of timing and phasing of provision of new infrastructure. There is no pressing need from existing Buckover residents for immediate housing, so there is time to get infrastructure sorted first.

The M5 J14 works completion exception in relation to housing delivery is not acceptable.  Wed_007 item 5.4 describes infrastructure delivery during the plan period. ‘In most cases, it is anticipated that the transport schemes will be completed either in advance of or during the early phases of housing build-outs in the relevant SDLs or Urban Living allocations (i.e. prior to completion of the first 25% of housing units). The main exceptions to this are: ...... M5 Junction 14, which is programmed to be completed around the middle phase of the Charfield SDL build- out (2027). ‘ 27

 Falfield Parish Council is extremely concerned that an exception has been made regarding the completion of the M5 J14 works in relation to JSP housing delivery. It is well known that M5 Junction 14 is already operating at beyond its safe capacity and there are significant projects already with planning permission in the locality and the adjoining county of Gloucestershire which will further increase demand on this overstretched junction imminently. The impact of new development at the three SDL sites of Charfield, Buckover and Thornbury are supposedly to be partly mitigated by improvements at Junction 14 and we expect assurance that housing and other vehicle trip generating developments at the Thornbury and Buckover SDL sites will not commence until the remodelling of M5 Junction 14 has been fully completed.

There is also a health and safety aspect to consider in the timing of the M5 J14 works due to the disruption of existing traffic flows around the junction during the two years of construction works to replace it as it is a key transport interchange. Alternative options to relocate the junction have not yet been tabled for discussion.

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We also query whether completion of the M5 Junction 14 works is actually achievable by 2027 as a business case has not yet been prepared, a proposed scheme design is not yet available, technical challenges have not yet been addressed and it is not yet included in the Highways England’s list of pipeline projects.

 The description of ‘local bus service improvements and local highways network improvements as necessary’ is deceptively vague and ill defined. How can such a vague description be costed and programmed adequately?

 It is also pointed out in item 5.54 and 5.97 that the SDL at Buckover Garden Village ‘would however not provide immediate access to a major employment area.’28 and ‘would only provide access to centres of a lower order (in settlement hierarchies)’29 performing negatively under Sustainability Appraisal objective 2E.

The Buckover SDL is predicted to only have limited access to substantial services and facilities  Item 5.22 states that the more rural locations (including Buckover) where new garden village style settlements are to be delivered will have limited access to existing services and facilities, particularly of a more substantial nature. It also states at SDLs which are in more rural areas, residents are still likely to be required to travel to existing town centres to access a more substantial range of services and facilities on a regular basis.30

Statistics provided imply that Bristol centric public transport measures are not relevant to half of the South Gloucestershire population.  The statistics given on page 120 of the Consolidated Sustainability Appraisal Appendices state that ‘commuting patterns are complex and trips across local authority areas are common. Data on travel to work patterns from the 2011 Census shows some 35,000 people travel to work from South Gloucestershire into Bristol to work each day and 29,000 travel in the opposite direction. A further 8,000 people travel from South Gloucestershire to work elsewhere in the West of England.’ This implies that less than half of the population of Buckover might (or might not) be attracted to any public transport provision running towards Bristol.

The Metrobus serving the Buckover SDL only offers public transport on a single linear route.  The Metrobus proposal for Buckover is only for one linear route into Bristol City Centre. The proposed Metrobus route does not having space for a dedicated lane or guide rails - just a normal bus service which will be caught up in everyday traffic. Our local residents currently need to travel to a multitude of destinations on a regular basis which will not be served by this single Bristol centric bus route which will have a long journey time. Our residents are just as likely, if not more likely, to prefer to shop (or work) in the town centres of Berkeley, Wotton-under-Edge, Cam, Dursley, Yate, , , Avonmouth, Severnside or further afield such as as alternatives to Thornbury and Bristol and there is no acknowledgment of this in the strategic proposals. Will the local bus service improvements encompass easy travel to these alternative destinations or not? What is the strategic proposal for getting Buckover residents to the Minor Injuries Unit or Council Offices or Benefits office in Yate or to our nearest major hospital at Southmead or the day treatment centre at if not by car? This still needs to be defined in the JSP and JTP and alternative public transport routes explored. More public transport choices needs to be offered for Buckover, than is proposed, to meet the aims of 3.4.1.31 P a g e 11 | 15

 On a similar note why is the Strategic cycle route only following the A38 Metrobus route, local residents may wish to cycle to other destinations safely. Why is it only from Thornbury and Buckover, why does the strategic cycle route not extend further up the A38 towards Falfield Village?

Falfield villagers do not benefit, they remain unconnected by the public transport measures.  Why does the indicative routing options for Metro bus illustrated stop short of Buckover,32 why does it not make any attempt to provide a route for our existing communities i.e. Falfield and the B4061 Are existing residents of the area expected to drive to Thornbury or Buckover to catch a Metrobus , as we have existing poor bus services. If so, where will they park? Just 100 spaces in a new park and ride further down the A38 will not cater for many existing residents and will not create much demand for the service as claimed.

Mitigation for increased vehicle flows on the A38 between Buckover and Falfield overlooked.  It is stated33 that ‘there will be large increases in flow between Buckover, Charfield and the North Fringe via M5 Junction 14; the impacts at Junction 14 will be addressed by the major junction improvement. Charfield station will play a critical role in providing effective travel choices and in helping to reduce the impacts at Junction 14.’ However no mitigation measures are mentioned, proposed or costed for the A38 north of Buckover through the hamlet of Whitfield and the village of Falfield which bears the brunt of all these larger increases in flow and significant delays on the way to Junction 14. This increase in traffic flow is clearly illustrated in figure 3.7. below.

 Table 3.534 illustrates a significant increase in the estimated vehicle trips per hour for the Buckover SDL forecast for both outbound and inbound traffic. The 11 hectares of employment land allocation at Buckover generates more trips than resident commuters. These figures are only based on 1500 houses not the future forecast of 3000 houses which is a concern.

 The phrase ‘local highway network improvements as necessary’ does not inspire confidence in the transport strategy for Buckover. M5 J14 is highlighted for improvement but where is consideration of improvements to the nearby traffic lighted junction in Falfield Village itself at the junction of the A38 and the B4509, which will also bear the brunt of all the extra northbound traffic from both the Buckover and Thornbury SDL’s plus the larger quantity of incoming employment traffic plus the forecast demand from other major developments in Gloucestershire County? Works at this junction are not included in the proposed programme or given a Capital Cost. WED008 Table 7.335 or highlighted on the map.32

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 Likewise, where is consideration of the mitigation measures for the existing stretch of the A38 between Falfield and the Grovesend Junction which will bear the brunt of the extra northbound traffic from both the Buckover and Thornbury SDL’s? How will the amenity of the existing residents living in very close proximity to this road be protected when they will be subjected to increased volumes of passing traffic and the noise and air pollution associated with this. WED007 Table 5.1.36 – refers to ‘Traffic management during construction along the A38 corridor, including key junctions between M5 J16 and Thornbury’ as a technical challenge but fails to consider the northbound stretch of A38 between Thornbury Grovesend junction and M5 Junction 14 at Falfield. This is not included in the proposed programme or allocated a Capital Cost. WED008 Table 7.3.35

Why is a Buckover ring road still not being considered as an option?  The Buckover Scheme has yet to be adequately master planned but where is any cost contingency for a ring road around its perimeter as previously suggested by South Gloucestershire Council, residents and businesses? The developer seems intent on opting for bisecting their garden village with the existing A38 (M5 relief road) yet history shows that comparable settlements in this through route situation have had to campaign for subsequent ring roads. Indeed, we note that other SDL’s sites being promoted such as Churchill, Banwell, and , Winterbourne and are including costings for a ring road – so why not include an allowance at Buckover too?

The Buckover SDL does not have good non-private car connections to Charfield rail station.  Charfield rail station reopening is being counted as a benefit to the Buckover development, but as reported ‘demand is largely limited to areas within 1km of stations’. Buckover is remote from the station and difficult to walk or cycle to due to the distance away, lack of footpaths, being cut off by the M5 and the steep terrain and poor bus services. An adverse impact also mentioned being a potential worsening of severance by the proposed works at M5 J14. Why are there no measures in the strategy to improve the route and public transport / cycle connections between Buckover and Charfield Station? This is not included in the proposed programme or given a Capital Cost. WED008 Table 7.3.35

Despite all the mitigations offered, the traffic situation is predicted to get worse after 2026.  The final paragraph of 3.2.2 states that ‘The increase in travel with more people living and working in the area will result in more traffic and more congestion on the network. Over the shorter term (to 2026) the delivery of the MetroBus and MetroWest schemes will mean a significant shift to public transport, which will help to mitigate growth in traffic and congestion. However, between 2026 and 2036, traffic growth will once again accelerate, with new parts of the network experiencing high levels of congestion resulting from longer-term growth.’37 This short term impact of Metrobus causes concern as the proposed A38 sustainable travel measures to benefit Thornbury and Buckover are not due to be completed until the period 2024 to 2027. After 2026 the traffic situation is predicted to get worse than at present. No proposals have been put forward to tackle congestion after 2026.

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In light of this the remote SDL’s such as Buckover clearly needs to have all of their programmed strategic infrastructure measures securely in place and completed before housing and other development commences. Each of the WED004H 7.8 Buckover SDL, WED_004I_7.9_Charfield SDL and WED004K_7.11_Thornbury SDL and requires wording to be added to this effect as it has been for some other SDL locations.

The Agricultural land classification map

BUCKOVER GARDEN VILLAGE

Cross References to Technical Evidence Work Consultation

1 WED 002 Schedule of proposed changes PC16 pages 8 & 9 2 WED 005 Updated viability assessment 3 WED 009C Appendix 7 pages 795 to 802 (note there is duplication of comments in the SA ESS Buckover pages 1 to 4 from November 2016 i.e. 444 to 447 digitally). 4 WED 004H SDL 8 Buckover JSP criteria 3pages 3 and 4 5 WED 009 Sustainability Appraisal of the West of England JSP Table 3.3 SEA Topic (f) soil page 36. 6 WED 009 Sustainability Appraisal of the West of England JSP item 5.58 page 114. 7 Wed 009C Policy 2 Spatial Strategy page 714. 8 WED 009C Appendix 5 audit Trail of the SDL options considered page 159. 9 WED 009 Sustainability Appraisal of the West of England JSP item 5.20 page 107. 10 WED 009 Sustainability Appraisal of the West of England JSP item 5.60 page 114. 11 WED 004G SDL 7 Nailsea item 8 page 4 12 WED 10A Updated Habitats Regulations Assessment Appendices Page 25 Appendix B.

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13 WED 10A Updated Habitats Regulations Assessment Appendices Page 52-53 Appendix D states that at Buckover further consideration of air pollution, recreational pressure and water quality/quantity is required as part of the Appropriate Assessment stage of the HRA 14 WED 10 Updated Habitats Regulations Assessment item 5.95 & 5.97. 15 WED 10 Updated Habitats Regulations Assessment item 4.86 & 4.91 Air Pollution. 16 WED 10 Updated Habitats Regulations Assessment item 4.87 & 4.92 Impact of Recreation. 17 WED 10 Updated Habitats Regulations Assessment item 4.88 & 4.93. 18 WED 004G SDL 7 Nailsea item 13 page 6 19 Wed 009C Appendix 5 Page 160. 20 WED 009 Sustainability Appraisal of the West of England JSP item 5.64 page 115. 21 WED 009 Sustainability Appraisal of the West of England JSP item 5.119 page 130. 22 WED 009B Addendum to the Consolidated Sustainability Appraisal Report page 14. 23 WED 009C appendix 3 Baseline information page 93 noise. 24 WED 009 Sustainability Appraisal of the West of England JSP Table 3.3 SEA Topic (c) human health - noise page 25. 25 WED 008 Emerging Findings Transport Report Table 7.2 Page 30 26 WED 009 Sustainability Appraisal of the West of England JSP item 4.132 page 85. 27 WED007 Transport Topic Paper 8 Page 49 28 WED 009 Sustainability Appraisal of the West of England JSP item 5.54 & 5.97 p 113&126 29 WED 009 Sustainability Appraisal of the West of England JSP item 5.88 page 124. 30 WED 009 Sustainability Appraisal of the West of England JSP item 5.22 page 108. 31 WED 007 Transport Topic Paper 8 3.41 Quality of travel choices pages 23 to 25 32 WED 008 Emerging Findings Transport Report Fig 7.1 Page 32 33 WED 007 forecast traffic flow differences in northern area Fig 3.7 page 28 34 WED 007 Transport Topic Paper 8 Table 3.5 Estimated trips per hour page 22 35 WED 008 Emerging Findings Transport Report Table 7.3 Page 31 36 WED007 Transport Topic Paper 8 Table 5.1 Page 47 37 WED 007 Transport Topic Paper 8 item 3.2.2 congestion page 16

Yours faithfully.

J. Carpenter Clerk & RFO Falfield Parish Council

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