Ref:

BROXTOWE BOROUGH, GEDLING BOROUGH and CITY

ALIGNED CORE STRATEGIES

WRITTEN REPRESENTATIONS FOR PUBLIC HEARING

OF

THE GEDLING BOROUGH COUNCIL CONSERVATIVE GROUP

MATTER 2

1 MATTER2: THE SPATIAL STRATEGY AND HOUSING POLICY

The Future of Broxtowe, Gedling and Nottingham City in the Context of Greater Nottingham

Population Trends

1. Whilst the figures within the document (Section 2.2.9) indicate a population growth across Greater Nottingham of 8.9% in the years 2001 – 2010, recently published figures from the 2011 census clearly indicate that population growth is by no means consistent across the area of the plan.

2. Nottingham City has experienced population growth of some 13.7% whilst Gedling Borough has only experienced growth of 1.6% with the population of the Borough rising from 111,800 to 113,600.

3. Net Migration within the Greater Nottingham area including Gedling Borough is generally negative with the only increase being within the 16 -24 year old age group. This in-migration is clearly linked to the success and popularity of the University of Nottingham and Nottingham Trent University. (Section 2.2.10)

4. It is a matter of fact that the bulk of the student population reside within the City of Nottingham and the areas to the South and West of the City. There is no evidence of any demand for additional student accommodation within Gedling Borough, nor, owing to the constraints of transport and distance, is there ever likely to be.

5. and Newstead are, as outlined within Section 2.2.10, primarily within the Travel-to-Work Area (TTWA) and not the Nottingham TTWA. (Section 2.2.10)

Connections

6. Much of the proposed new residential development within Gedling Borough is to be situated within the Parished Areas to the North and East of the Borough, rather than adjacent to the PUA’s of Arnold or Carlton. These are areas which in many cases have insufficient public transport links to the City of Nottingham and where the road infrastructure is woefully inadequate in terms of being able to accommodate the level of additional traffic that is likely to be generated by the size and scale of the proposed developments.

2 7. As identified in Section 2.2.16 there is already significant traffic congestion during peak hours on main radial and orbital routes across the area.

Green Infrastructure, Open Space and Landscape

8. As identified in Section 2.2.22 ‘the area’s countryside and open spaces are an important part of its local distinctiveness’ and the size and scale of the proposed developments within the Parished areas will seriously erode the green corridors which ensure the distinct individual identities of the rural villages.

9. The proposals for the development within the Parish of Linby would, if approved, lead to the creation of a new ‘town’ within the Parish of 1,000 plus new residential homes, plus additional commercial and industrial sites. This would make the existing historical conservation village of some 86 properties no more than an adjunct to the new development.

10. Similarly the build of 600 new properties on land north of Papplewick Lane, on land within Gedling Borough but adjacent to the PUA of , would virtually link the conservation village of Papplewick to the Sub-Regional Centre of Hucknall by eradicating much of the Open Space between the two settlements.

Spatial Vision

11. This element of the consultation document which is intended to reflect back from a future 2028 to the present time refers to the completion of ‘30,550 new homes developed since 2011’ (Section 2.3.3) and I quote ‘sustainably accommodated within the existing built up area of Nottingham which has assisted in reducing the need to travel, made the most of existing infrastructure and has driven the regeneration of parts of the urban area. The built up area of Nottingham has been expanded and new development is creating successful communities, well integrated into the urban area, and with excellent connectivity to the wider city, especially the City Centre and other job opportunities.’

12. It is difficult to reconcile this statement with the intention to construct huge residential developments within the rural Parish areas, remote from the City of Nottingham, with insufficient road infrastructure and little public transport, in villages in which there is a total reliance on the private motor car as a means of transport and in which there are little or no commercial or industrial job opportunities.

Spatial Objectives

13. Section 2.4.1 makes the first of many references to the Gedling Colliery/Chase Farm site in Gedling Borough, but whilst this substantial brown-field site is referred to throughout the document as a site of possible future development,

3 there is no strategy evidenced for making this site accessible and deliverable, nor is there any element of housing provision allocated to it. This despite the fact that the majority of the funding for the Gedling Access Road (GAR) has now been secured, which will allow this site to take its proper place in the available site hierarchy, thus reducing the element of Greenfield sites required to accommodate the headline requirement figure of 7,250 new residential properties.

14. The plan within Section 2.4.1(ii) instead refers to the SUE’s at Top Wighay Farm and North of Papplewick Lane to the north east of Hucknall as supporting the regeneration of Hucknall as a Sub-Regional Centre, notwithstanding that the relevant Local Authority, Council, are openly hostile to these developments.

15. Additionally the Key Settlements of , Calverton and Ravenshead are to be developed ‘to make the best of their accessibility to services and infrastructure capacity’.

16. Bestwood Village has one corner shop, no public house or Doctor’s surgery and a Primary School that is over-subscribed. It operates an hourly bus service on week- days only and has one significant road, Moor Road, into and out of the village.

17. Calverton, it is accepted, is better placed in terms of a village centre, Doctors Surgery, schools and public transport but has already suffered heavily in recent years in terms of substantial infill and new development.

18. Ravenshead, as already identified is primarily within the Mansfield TTW area, has an over-subscribed Doctors Surgery, Primary Schools both to capacity, and a small privately owned shopping complex and is already the area of highest in-fill development (garden-grabbing) within Gedling Borough.

19. Ravenshead has traditionally had defensible boundaries of Main Road to the North, Chapel Lane to the East, Nottingham Road (A60) to the West and Kighill Lane to the South. Those boundaries have become blurred in recent years with some development on Green-field sites to the east of Chapel Lane and proposals within the plan would erode the boundary to the north, by potentially allocating development between Main Road and Ricketts Lane, thus narrowing the green corridor between the village of Ravenshead and the Harlow Wood development in Ashfield.

20. Quite where the referred to ‘services and infrastructure capacity’ is to be found is somewhat of a mystery to the respective Parish Councils and their communities.

21. Section 2.4.1x refers to the aspiration of Excellent transport systems and reducing the need to travel: to ensure access to jobs…..reducing the need to travel especially by private car…

4 22. As already outlined these identified ‘Key Settlements’ have little or no employment opportunities, are isolated in rural areas and would require a great deal of ‘need to travel’ to offer any form of employment to their enhanced and enlarged communities.

Gedling Spatial Portrait/Local Distinctiveness

23. As identified in Section 2.8.1 Gedling Borough is a mix of urban and rural with around 80% of its residents living in the Greater Nottingham suburbs of Arnold and Carlton. The reason for this is quite simply that the bulk of residents, who do not actually serve the commercial or service industry requirements of the immediate area itself, are employed within the Greater Nottingham area. (Section 2.8.6)

24. Transport links between the different settlements within the rural parts of the Borough are poor with some of the rural settlements being relatively isolated. (Section 2.8.1.)

The Delivery Strategy

Policy2: The Spatial Strategy

25. We have already referred to the anomaly of Bestwood Village, Calverton and Ravenshead being identified as Key Settlements for growth. (Section 2.c.) ii.)

26. Within the overarching figure of 7,250 new homes identified for Gedling Borough and despite all the references to the need to site new developments adjacent to and supportive of Greater Nottingham itself, for all the reasons already identified above, only 2,840 of the new Gedling homes are to be sited in or adjoining the existing built up area of Nottingham. (Section 3a.)

27. This leaves some 60% of the proposed new development therefore to be built on green-field sites in the rural Parished areas of the Borough, which appears contrary to all the rhetoric contained within the strategy document as to the need to align with and support Greater Nottingham itself.

28. Again the brown-field site of Gedling Colliery/Chase Farm is referred to in passing as an area of future housing development only (Section 3a) i.)

29. Section 4 g) and (5 with reference to retail development) for the first time makes reference to the Gedling Colliery/Chase Farm site with the addendum if development commences in the plan period and Section 6 b) i) Highways Improvements identifies the site as a scheme with no committed funding, but which remains important to the delivery of the Core Strategy. However it is worth mentioning again that there is no identified strategy to help to

5 deliver this important brown-field site and since publication of the original consultation document significant funding has now been provisionally agreed.

Housing Provision

30. In re-iterating the housing provision for the three council areas of 30,550 the document links that number to ‘meeting the needs of the existing population whilst allowing for continuing migration to the area, albeit at a lower level than that experienced in the past’. This reference appears to relate solely to the needs of Nottingham City rather than the needs or identified requirement of Gedling Borough. (Section 3.2.6.)

31. Section 3.2.7 again makes the link to the figures being based on the now abolished Regional Plan

32. Of interest is the comment in Section 3.2.8 which identifies that the housing projections are considered to be extremely challenging in terms of delivery and that even in the boom and bust years of the last decade, only on three occasions has delivery matched these projected figures.

33. In light of the very difficult financial climate in which the country finds itself there is reason again to challenge the realistic nature of the projected housing figures with reference to both requirement and deliverability.

34. Section 3.2.10 refers to the SUE’s at Top Wighay Farm and North of Papplewick Lane and also alludes to Ashfield District Councils own proposals to develop on brown-field land to the south of Hucknall which, in terms of size and scale relevant to the supporting infrastructure of Hucknall, raises serious questions as to the viability of the Gedling proposals.

Gedling Borough

35. It is interesting to note the entry at Section 3.2.23 that ‘The Borough remains committed to the long term policy of urban concentration and regeneration’. This appears to fly in the face of the 60% development in the Parishes and the total failure to consider or advance the development of the Gedling Colliery/Chase Farm site.

36. Section 3.2.24 appears to recognise the contradiction self-evident in the section above and attempts to qualify itself by stating that the ‘redevelopment of Gedling Colliery/Chase Farm is a key strategic site on the urban edges of Nottingham…’ However there is no discernible strategy or plan to move the Borough forward in respect of this ‘key’ site.

6 Other Spatial Priorities

37. Section 3.2.34 identifies that ‘Transport is a major contributor to climate change and congestion has adverse economic impacts, as well as being detrimental to air quality. The lack of inclusion of New Farm, Redhill appears to be as a result of both a lack of infrastructure in allowing access to the A60 and concerns as to air quality on the A60 Redhill corridor.

38. However the same traffic from the proposed developments at Ravenshead and indeed a degree of traffic resultant from the Top Wighay and North of Papplewick Lane proposals will invariably use the A60 Redhill corridor to access the Greater Nottingham area. It will just have to travel much further and residents will have less access to alternative public transport.

39. It is concluded therefore that the lack of a strategic plan to allow for the development of accessibility to the New Farm site will merely exacerbate rather than reduce the problem.

40. Section 3.2.36 is interesting in that it clearly indicates that the proposals for the Key Settlements for Growth (Presumably the green-field sites of Bestwood Village, Calverton and Ravenshead) are largely due to the inability to deliver, in the early stages, development on the brown-field site at Gedling Colliery/Chase Farm. Thus indicating that in order to achieve the numerical requirement for 7,250 new homes, as outlined earlier in the Aligned Cote Strategy, it is an either/or situation.

41. Regrettably this does not sit comfortably with the already identified lack of any strategy to deliver on the Gedling Colliery/Chase farm site and the apparent ‘fall- back’ status now accorded to that site with the comment that ‘…..it could be a contingency site if development elsewhere not be delivered as planned.’

42. Whilst accepting that there has to be a starting point for any plan or strategy the failure of the Planning Authority to build in appropriate flexibility to allow for a rapidly moving and changing planning environment is disappointing.

43. Despite new residential sites coming forward between the self-imposed cut-off date of April 2012 and the Public Examination. Gedling Planning Development Officers have failed to address their potential contribution to delivery or to take the opportunity to relieve the pressure on greenfield-sites by their subsequent inclusion in an up-dated strategy.

44. Additional capacity, not least at Teal Close, Spring Lane and Rolleston Drive, Arnold has been identified but does not appear to directly feature within the document under examination, notwithstanding that in respect of Teal Close at least, a planning application is currently being determined by Officers which would potentially add over 400 homes to the equation.

7 Policy 3: The Green Belt

45. Section 3.3.2 recognises that ‘….the original purposes of Green Belt as set out in the NPPF Framework will be an important consideration, in particular, the need to prevent coalescence and maintain openness.

46. It is worth considering this observation when noting, in particular, the proposed SUE’s at Top Wighay and the extension of development in Ravenshead into the land between Main Road and Ricketts Lane. Both of these proposed developments, coupled with that of the land North of Papplewick Lane (albeit safeguarded land) have the potential to allow the very coalescence that the above statement is designed to avoid.

Policy 6: Role of Town and Local Centres

47. Section 3 again emphasises the potential advantages of developing the Gedling Colliery/Chase Farm site but also applies the caveat ‘if development commences in the plan period’. Again then the observation is made that there is no provision within the plan for this site to be advanced.

Policy 7: Regeneration

48. Section 1 e) states that ‘Gedling Colliery/Chase Farm offers the opportunity for the redevelopment and reuse of brown-field land to create a new sustainable neighbourhood, if development commences in the plan period. It will be designed to engender a safe and strong community and to create a place of distinction and will require the construction of the Gedling Access Road.’

49. At the risk of repeating earlier observations, this site is referred to throughout the plan, in virtually every context and yet there remains no strategy or constructive aspiration for delivery.

Policy 8: Housing Size, Mix and Choice

50. Section 3.8.2 in relation to the increase in smaller households cites one of the main factors as being down to an ageing population.

51. Section 3.8.4 states that ‘Emerging older persons research indicates that a majority of the elderly population interviewed would wish to remain in housing that they currently occupy for as long as possible. Respondents to surveys have also indicated that if they had to move to properties in the future their aspirations would include 2 bedroom bungalows or purpose built ‘retirement villages’.

52. Whilst it is accepted that this document is a strategic plan it is worthy of note that any element of affordable housing should include such properties for those residents who are equity rich, but cash poor and who currently continue to occupy

8 large family homes, where a partner or spouse may have passed on and children have long since established their own households. This would allow for an enhancement of the quality of life of the elderly resident, in an area that they are familiar with and would allow for the freeing up of family homes to regenerate ageing communities.

53. Policy 8: Section 9 – Approach to Rural Affordable Housing appears to support this case in stating that ‘In allocating rural affordable housing, priority will be given to people that have a connection to that settlement who are unable to afford market housing’.

Affordable Housing

54. Section 3.8.12 in referring to the Nottingham Core Strategic Housing Market Area Assessment refers to an affordable housing provision for the three councils of 19,210, representing approximately 63% of the total housing provision of 30,550 for the plan area.

55. Policy 8: Section 5b) gives a variable allocation of affordable housing provision of 10%, 20% and 30% depending on location.

56. It is important that new housing is of a similar character and design to existing development and that any new buildings enhance and complement the characteristics of an area or community. Urban designs are not always appropriate to rural areas and clearly visa-versa. An over-abundance of affordable properties would clearly be inappropriate in an area where, by their scale and design, they were clearly out of keeping with existing properties.

57. The viability of affordable housing is not merely down to whether or not the development can bear the cost of a greater or lower number of such properties, but also as to whether there is a real demand in some rural communities where there is no local employment, there is a requirement for private transport and people are simply parachuted in by a Local Authority, despite the fact that they have no links to that community or desire to live there.

Policy 10: Design and Enhancing Local Identity

58. Section 1 c) new development should be designed to reinforce local characteristic is vitally important and sits comfortably with Paragraph 63 above.

59. Section 3.10.4 states ‘Although now considered to be green-field sites, gardens can provide sustainable locations for new homes and reduce the need to develop land within the Green Belt and or the countryside. However it can also change the characteristics of areas and may damage biodiversity. In accordance with this policy and the NPPF, subsequent Local Development Documents may seek to

9 restrict development to avoid areas of special character and to protect the amenity value of private gardens.

60. We welcome some added protection to Planning Authorities to restrict ‘garden- grabbing’ which has led to significant infill in some areas and changed the whole character and layout of communities and trust that this will be rigorously applied by Planning Officers

Policy 14: Managing Travel Demand

61. The proposals to build 60% of new development over the next 17 years in the Parishes seems to be at odds with the statement in Section 1 that ‘the need to travel, especially by private car, will be reduced by securing new developments of appropriate scale in the most accessible locations following the Spatial Strategy in Policy 2.

62. As already highlighted, significant development in rural areas will merely exacerbate transport and travel problems by virtue of their remote locations away from main arterial routes, where public transport is inadequate and where the ownership and use of private vehicles is essential and not optional for day to day existence.

63. Policy 14: Section 3 d) in referring to a hierarchical approach to the delivery of sustainable transport networks makes reference to highway capacity enhancements to deal with residual car demand.

64. We would make the point that in certain conservation villages, such as Linby and Papplewick, there is little that can constructively be done to significantly improve key congestion points, simply by virtue of the fact that these junctions and crossroads were designed for the horse and cart and not modern vehicular traffic and are bounded on either side by heritage buldings.

65. Section 3.14.1 refers to ‘the key element of this policy being to encourage development in locations which support the promotion of sustainable travel choices as alternatives to the private car, in particular good quality public transport and safe and attractive routes for cycling and walking.’

66. We have already referred in some detail to the relative isolation of rural villages, the lack of sustainable public transport within and out of such locations and their relative distance from any form of realistic employment. Whilst indeed safe and attractive routes for cycling within, they are certainly not safe and attractive routes for cycling or walking to and from, invariably having no pavements and leading cyclists directly towards heavily used A-class roads.

10 Policy 15: Transport Infrastructure Priorities

67. Section 4 prioritises the deliver of the Gedling Access Road as a scheme with no committed funding but which remains important to the delivery of the Core Strategy. We would dispute the fact that there is no committed funding but do identify that there is no coherent strategy for delivery within the lifetime of the plan.

Policy 19: Developer Contributions

68. Section 2 informs us that ‘The Councils intend to introduce Community Infrastructure Levies (CIL) to secure infrastructure that has been identified as necessary to support new development and to achieve Core Strategy objectives.

69. Section 3.19.3 goes further in announcing that Gedling Borough Council is advancing the development of CIL as one of the Government’s ‘Front Runners’ with close liaison with other Councils.

70. However the plan is silent as to how CIL is already intended to be used to support the swift delivery of the Gedling Access Road, support the residential and commercial development of that site and the regeneration of the area and thus obviate the need for significant aspects of green-field development.

Appendix C – Housing Trajectories

Gedling Trajectories

71. Total build in Gedling in the years 2001 – 2011, a period of relatively strong construction activity, certainly in the earlier years, regardless of the economics underpinning it, were in the region of 2720 completions. An average of 272 new- build residential properties per annum.

72.The Aligned Core Strategy projections giving a figure of 7,250 new build requirements would, over the 17 year period of the plan, require the construction, at a time of great economic uncertainty, of some 426 properties per annum.

73. Notwithstanding the fact that that the above figures are totally unrealistic in themselves, we would contend that there has been no realistic or sensible assessment of the likely impact of ‘windfall’ sites within Gedling.

74. Firstly, let us make it clear that we fully understand that it is obviously difficult to fully and accurately assess windfall projections, because they are a ‘moving feast’ which depend upon outside influences and a degree of speculation.

11 75. However new Central Government guidance indicates that projected windfalls can now be taken into account when assessing future housing provision as long as the figures used are robust and based upon a sound evidential footing such as historical data.

76. Included in the Aligned Core Strategy Gedling projection is a windfall figure of 200 on the basis of 40 completions per annum over the last five years of the plan only.

77. Contrast this with accurate historical data for windfalls within the Gedling Borough Area of the following:

Year 01/02 02/03 03/04 0405 05/06 06/07 07/08 08/09 09/10 10/11

PUA 127 201 335 192 227 249 333 112 174 143

Non - 10 14 40 56 33 40 42 31 38 63 PUA Total 137 215 375 248 260 289 375 143 212 206

Total Windfall Completions 2001 – 2011 of 2460 Properties

Annual Average of 246 per Annum

78. Clearly on the basis of the figures as outlined there is significant scope for the inclusion of a far greater number of potential windfall completions which would by definition reduce the requirement for the huge number of proposed new-builds on green-field sites within the Borough and predominantly within the rural areas.

Conclusions:

79. The Conservative Group feel strongly that the Aligned Core Strategy Publication Document is based on a flawed assumption of far greater housing need than is required within Gedling Borough based on historical data and net migration.

80. The plan fails to give due weight to the appropriate inclusion of historical windfall data and reflect future anticipated windfall provision.

81. The plan allocates far too much of the housing to rural areas and to Sustainable Urban Extensions adjacent to a Principal Urban Area, for which the Authority has no locus, against the wishes of the relevant Administrative Authority.

12 82. The plan fails to adequately address the issue of Gedling Colliery/Chase Farm and whilst making continuous reference to it, as a strategic site in all categories of the plan, is totally silent as to how and when it may be strategically addressed and brought forward as the principal brown-field site within the Borough.

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