New South Gloucestershire Local Plan 2018

Home , A38 road, Falfield, Milbury Heath

Local Plan 2018 - 2036 Prospectus (For official use only)

Please return to: Strategic Planning Policy and Specialist Advice Team, South Gloucestershire Council, Department for Environment and Community Services PO Box 299, Civic Centre, High Street, Kingswood, Bristol, BS15 0DR or if in electronic form by email to [email protected].

Responses must be received by Thursday 23th February 2017

Information on the new South Gloucestershire Local Plan, including the opportunity to respond online, is available at www.southglos.gov.uk/newlocalplanprospectus.

1. Personal Details (or client details if applicable) 2. Agent’s Details (if applicable) Title Mr

First Name James

Last Name Carpenter

Job Title Clerk (where relevant) Organisation Falfield Parish Council (where relevant) Address Line 1 Whitegates

Line 2 Sundayshill Lane, Falfield

Line 3 Wotton under Edge, Glos

Post Code GL12 8DQ

Telephone Number 01454 260433

E-mail Address [email protected]

Ref Number (if known)

(IF YOU PROVIDE AN EMAIL ADDRESS WE WILL USE THIS TO CONTACT YOU) The information collected as part this consultation will also be used by the council in accordance with the data protection principles in the Data Protection Act 1998. The purposes for collecting this data is: to assist in plan making; and to contact you, if necessary, regarding the planning consultation process. Some of the data may be made public as it will form part of the evidence base used to inform the creation of planning policy documents. The above purposes may require public disclosure of any data received on the response form, in accordance with the Freedom of Information Act 2000.

Keeping in touch You can register to be kept informed of progress with the new SGLP using this LINK and selecting ‘planning policy and strategy’ in the ‘topics of interest’ section.

Page 1 of 21

Q1. We are keen to know what cross boundary strategic matters neighbouring authorities, government agencies etc. would like to engage with us on and which methods of engagement would best suit.

Falfield Parish is on the boundary with Gloucestershire County Council and Stroud District Council Their decisions on development, highways and public services are as relevant to us as those of South Gloucestershire Council. The impact of any development north of South Gloucestershire needs to be taken into consideration as well as that of Highways England in relation to the M5/J14 motorway.

Q2. Are the key priorities identified in paragraph 3.8 and in Topic Paper 1 the right key priorities for the South Gloucestershire new Local Plan to tackle up to 2036?

Section 5.3 and Topic Paper 1 “Local Plan Key Priorities”. The key evidence base in this section should also include the south west regions agricultural land classification maps. Higher quality agricultural (Grades 1, 2 & 3) should be protected to provide food and non-food crops for future generations. Lower quality agricultural land, i.e. grades 4 (poor) and 5 (very poor) should be considered for re-use allocation first.

Section 5.5 (Call for Sites). Landowners and developers should not be allowed to “call the shots” in deciding which land should be considered. This should be a strategic process and not a piecemeal process depending on what may or may not crop up under the call for sites.

Q3. Have you any comments on what should be included in the visions for any of the following areas: 1. Overall vision for the whole of South Gloucestershire 2. Urban areas in the north and east of Bristol 3. Yate & Chipping Sodbury 4. Thornbury 5. Severnside 6. Rural areas

As a Parish Council we can only provide comment on our own area of Falfield Parish which is a rural parish. The innovative transport solutions referred to in the SGLP prospectus is too vague. A recent planning application for large scale development in the village was refused on the grounds that the proposed development was unsustainable due to the location of the site and its distance to available services, facilities and employment and the high reliance on the use of the private motor car. Going forward the Parish Council believe that this position would remain unchanged.

Page 2 of 21

Q4. Is the draft structure the most appropriate approach?

Falfield Parish Council believe that the prospectus is too long and contains no real substance

Q5. Do you consider the approach to combining policies and the range of policies identified is appropriate to address the land use issues facing South Gloucestershire

As a small rural Parish Council we are not policy makers or qualified to understand all the policies. We are more concerned on what policies have been left out of the prospectus, for example agriculture and health than those that are identified.

Q6. Are there other policies that are needed to address the land use issues relevant to South Gloucestershire?

As mentioned in Questions 2 and 6 there is no mention of an agricultural policy.

Q7. As part of this consultation additional sites and evidence supporting their deliverability can be made using the online response form available from www.southglos.gov.uk/callforsites

Please ref to our site specific comments in relation to the following:  Parish Councils response to the JSP (copy attached, pages 5 to 13)  Parish Councils response to Planning application Ref: PT16/0770/O (copy attached, pages 14 to 21) which was refused by South Gloucestershire Planning Committee on the grounds that the application was un-sustainable.

Page 3 of 21

Q8. Do you have any comments on the methodology used to construct the Sustainable Access Profiles? For example comments on the approach to defining the range of key services and facilities, assessing walking and cycling and public transport access.

What criteria have been used to decide where will be profiled where there is no settlement boundary. We note that some local areas have been missed out, e.g. Tortworth and Leyhill and yet other small hamlets such as Latteridge, Hill and Rockhampton have been included.

Although the importance for access to Superfast Broadband has been reduced in importance as a result of a consultation in 2015 Falfield Parish Council believe that as a rural parish it is important to have Superfast Broadband in order to be able to communicate to the wider world. The sustainability profile for Falfield is misleading in that it states that Superfast Broadband is available to the Village which is incorrect with less than approx. 10% of the parish able to access this facility.

Q9. Do you have any comments on the findings and detail of individual Sustainable Access Profiles? E.g. are certain key services and facilities included which should not be, or are others missing?

The location on the map for the Community Centre for Falfield is incorrect. The Parish Council would also question whether Falfield Village Hall could be considered a Community Centre as it is not open on a regular basis. Also Falfield Parish Council does not believe that Falfield Cars (now known as Happy Auto’s Ltd) can be classed under the heading of a “Comparison Store” within its current footprint.

Page 4 of 21

Clerk: Mr James Carpenter, Whitegates, Sundayshill Lane, FALFIELD Falfield, Wotton under Edge Glos. GL12 (01454) 260433 PARISH COUNCIL [email protected]

West of England Joint Planning Consultation C/O South Gloucestershire Council PO Box 299 Corporate Research and Consultation Team Civic Centre High Street Kingswood Bristol BS15 0DR

18th December 2016

Dear West of England Joint Planning Consultation Team, The following comments are the observations received from parishioners and that of Councillors from the parish of Falfield.

The Preferred Spatial Strategy does not offer the most appropriate strategy for the area, there is a lack of in depth investigations and there are other alternatives which have not been adequately explored. There are reasons why this strategy and the identified location at Buckover could not and should not be delivered and we outline why in more detail below.

We fully understand that further housing needs are to be provided within the West of England Region and that the option of creating a new settlement is one of just a number of approaches under consideration and consultation. We also understand that the “Garden Village” model is an untested approach within South Gloucestershire and with it carries a higher risk of failure and unviable infrastructure commitments which is a concern to the local community and Council tax payers.

At this point we would like to repeat our comment made on the initial JSP consultation regarding the safeguarding of green belt where we felt that under this approach, inappropriately large volumes of housing could end up far away from the centre of the city of Bristol intruding into the rural countryside. This would also allow the urbanisation along the northern boundary of the Green Belt, where it is least sustainable and with an increase

Page 5 of 21 in people commuting back and forth into Bristol. This would mean that over time Falfield along with other local villages would become a suburb on Thornbury.

Firstly, the strategy relies on a suitable location being found for the new settlement. DCLG guidance for new garden villages recommends that any location has the support of the local community. Ideally it would be in a discrete location, away from existing settlements, on a brown field site, in a location where it does not unbalance, overwhelm or change the character of an existing community and put undue strain on the local services. To be successful, the settlement should aim to offer improvements to local infrastructure and be sustainable; it should not worsen situations or increase congestion problems.

Car ownership should not be essential as there should be a range of cheap public transport options available to quickly access a variety of major employment zones, including access by rail, bus, cycling and walking. There should be easy access to hospitals. Emergency services provision from the ambulance, fire and police services should be quick, reliable and safe. Implementing the new settlement should not force local companies out of business. It should not jeopardise endangered species out of their habitats or destroy sites of national importance.

We can only answer for our own area, along with our own knowledge that we know this area. The proposed site at Buckover FAILS on all of the above counts. We are not opposed to housing development but feel that this is the wrong location for a proposed new settlement and we outline our reasons and observations of parishioners in more detail below:

Buckover is not a Brownfield site

The proposed site for ‘Buckover Village’ is not a brown field site or previously developed land; it is open countryside and good, versatile, farming land on the edge of the market town of Thornbury. The South West Regions agricultural land classification maps classify 70% of the proposed Buckover site as 'Grade 2 Very Good' agricultural land and 30% as 'Grade 3 good to moderate' agricultural land. The location is higher quality land which national planning policy says should be protected to provide food and non-food crops for future generations.

We also understand that the ‘Garden Village’ model is an untested approach within South Gloucestershire and with this it carries a higher risk of failure and unviable infrastructure commitments which is a concern to the local community and Council tax payers.

Tenant farmers would lose their businesses

Our local farmers, who run successful local dairy and arable farms and have been farming the land subject to this proposal for generations are devastated by these proposals, as it would remove their homes, their livelihoods and a source of employment for our local farming community.

Page 6 of 21

The proposed Buckover Village is out of scale

The number of dwellings proposed is not of the typical scale of a rural South Gloucestershire village. At 2200 to 3000 dwellings, Buckover would become the third largest town in the county. It is over thirty times the size of Falfield village which historically is the centre of Falfield parish, it is an imbalanced and wholly out of scale proposal for the local area.

We are reiterating that we are not “NIMBY” Parish Council

Our rural parish community of 228 homes has already committed to a 20% growth in its new housing numbers over the last ten years. In addition to this we have a planning application pending consideration which would increase the number of houses in our parish by a further 50%. An additional housing development of this scale would irreversibly destroy the character of our local community and our farmland countryside and this should be given due consideration.

Buckover is not a discrete location

The ‘Buckover Garden Village’ site is not located discretely; to the contrary the site is in a prominent location on undulating agricultural land, sloping steeply in parts, which is visually important upon the northern approach into South Gloucestershire and the West Country. There are many distant views to the site from the hills of Gloucestershire and across the Severn Estuary. South Gloucestershire Council have previously designated this land in their own documents as a ‘Visually Important Hillside’ and an important part of the County’s ‘Strategic Green Infrastructure’. The proposal will cause irreversible harm to the character and appearance of our local area.

The Village Garden Concept would be of no benefit to the existing communities

DCLG guidance suggests that new garden villages should have the support of their existing local communities, however the Buckover proposal as presented in the JSP and JTP appear to offer little benefit to the existing parishioners of Falfield or to the neighbouring town of Thornbury and does not have their support. The suggestion of improvements to a motorway junction (which may never happen) in no way mitigate the detrimental effect the resulting significant increase in traffic congestion, the strain on local services and facilities and the total change in character of the local landscape would have on the local communities. History dictates that the creation of major employment around local communities has changed with workers looking further afield from their place of living. This is confirmed in the 2011 census which records that the average distance commuted to work in England and Wales increased from 13.4 km in 2001 to 15.0 km in 2011.

Page 7 of 21

The Buckover location is an extension to Thornbury not a new settlement

The proposed sites very close proximity to Thornbury means that the ‘Garden Village’ would become a suburb of the existing town. The ‘constraints’ map displayed as part of the JSP, illustrates recent and proposed housing developments around the perimeter of Thornbury which further infill the very small gap between the existing town and the proposed ‘Buckover Garden Village’ boundary. Any village would struggle to have its own identity in this location. The hamlet of Whitfield is surrounded by and consumed by the proposals. Buckover would simply be viewed as a large housing estate on the edge of Thornbury that you drive through to get to the town. It is not a self-sufficient stand-alone proposal – the location is wrong.

The Buckover location will have no sense of identity

The proposed location for Buckover straddles the busy A38 located beside the M5. This location would create a bisected community from the outset - a place known for passing through or sitting in a traffic queue, rather than a place with its own clear identity, this is detrimental to trying to create any sense of community and the proposed location is clearly wrong. This is the very reason for not extending nearby in Alveston. The West of England Partnership and South Gloucestershire Council would be better placed to invest in trying to create a new community in a well-defined location with its own clear identity which does not have these insurmountable conflicts and constraints which would forever be a problem for the town planners.

It is a noisy location

The A38 and the M5 are significant noise generators day and night. During busy periods the noise generated by the traffic passing through at speed is at a high level and heard from both inside and outside existing dwellings. Existing residents of the parish will tell you that they struggle to hear their neighbours speak in the street at busy times. This is not conducive to a sense of community, particularly when a major transport route such as the A38 passes through the centre of a settlement, it is an unsuitable location. Any development would require acoustic treatment which is very costly and would lead to less opportunity for affordable housing.

It is detrimental to the local highway infrastructure

Due to its location, distant from any railway and regular bus services, the proposal will likely be highly car dependent. This is not sustainable and there are concerns that this will have a detrimental impact on highway safety both locally and on the motorway network, parts of which are already operating at capacity. Congestion on the A38 is worse year on year and traffic is often at a standstill at peak commute times, on bank holidays and school holidays or when the motorway has to close or is congested. All other roads in the vicinity are narrow rural lanes, most without footpaths and there is a risk that as the main roads become more congested that the rural lanes will be used as rat runs which will impact on highways safety for all local users. The location of the Buckover site goes against the aims of the JSP to reduce car usage.

Page 8 of 21

The status of M5 Junction 14 is unknown

Junction 14 of the M5 has recently been reviewed by Highways England and it is projected to have capacity problems before schemes already included in existing Local Plans have been implemented. The junction requires replacement however this is not factored into the JTP and there is no design, plan or timetable yet set for undertaking this. To put this in context, it has taken approximately 25 years to only get as far as a feasibility study for the new junction on the M4 south of Yate. For highway safety reasons, no part of Buckover, which relies heavily on car transport and this junction, should proceed before the junction is replaced. As the timescale for the junction replacement is unknown, surely the timescale for implementing Buckover is also unknown and this is a risk in terms of committing to housing supply delivery over the term of this JSP. For this reason Buckover is therefore an unreliable location to include in the current strategic development framework for the West of England to 2036.

The existing bus service provision is inadequate

Existing public transport provision in this extremity of the west of England region is poor and suffers frequent cutbacks and change of routes. The times taken to travel by bus into Bristol city centre are excessively long and costly per return trip. It is not currently possible to commute to and from major employment outlets via public transport and work a traditional 9 to 5.30pm working day. The metro bus currently being installed in Bristol is only projected to cut 5 minutes off journey times, this type of service is little incentive for those facing such lengthy commutes.

One Metro bus route is inadequate

This is an unproven transport strategy which has yet to be fully implemented in Bristol. It is proposed in the JTP that Thornbury / Buckover may or may not be served by just one southbound route, along the A38. This may suit a minority of people who work along that single route but the majority of the current population work in a wide range of locations to the north, south, east and west of the county and would still have to rely on car transport to commute to work as there is no other reasonable alternative in existence or being included in the strategy. The Metro bus does not accept bicycles on board making it incompatible for those who then need to travel on any distance away from the bus terminals.

The location has no local access to rail infrastructure

The nearest main railway station in South Gloucestershire is at Bristol Parkway and Cam in Gloucestershire. To both locations is a 30 minute drive at non peak times , there is no direct road or bus route or safe cycle route from Buckover to either of these stations and the car routes involved i.e. the A38, Aztec West, are already heavily congested. You cannot walk or easily cycle to rail transport and parking at these stations is unreliable and expensive.

Page 9 of 21

Buckover will become a commuter village

Being in such a remote location on the extremities of the West of England area and as distant from the city centres of Bristol, Bath and Gloucester are as far as you can get from this location. Buckover will encourage commuting by car and increase congestion which goes against the aims of the JTP. Its proximity to M5 Junction 14 and poor public transport connections implies that cars should be relied upon. There are no major employers within walking or cycling distance of the proposed site and even if one was introduced that would not solve the commuting issue as you cannot control where people work and the residents of all settlements tend to work in a diverse range of employment sectors.

Public Parking facilities in Thornbury are inadequate

The public car parking in Thornbury Town centre is already inadequate during peak times with no proposals for expansion. The distance between Thornbury and Buckover is too great to encourage walking and the route from Buckover, crossing the A38 is already classified as a hazardous route for school children. Residents should not be expected to drive back and fore between Buckover and Thornbury to access shops, services or the Metro Bus. There is a risk that any newer facilities in Buckover will compete with those of Thornbury High Street and lead to its decline.

Local services will be adversely affected

There is no strategy tabled for discussion to explain how necessary services i.e. doctors surgeries, Dentists, schools, hospitals will be provided to cater for the proposed residents.

The Buckover settlement may impact on local and regional service provision to the detriment of our parishioners who already experience lengthy waiting times.

The ambulance service struggles to support the area

This is a rural area and a poor choice of location in terms of access to emergency care. It takes a significant long time to drive to Southmead Hospital, our main regional hospital and at peak times ambulances already fail to respond to dire emergencies in the area within adequate time. The response times for Red 1 & 2 calls for GL12 is just 38% when the target is 75%. This is a fundamental public safety concern for all existing and the proposed residents. As a comparison, inside the green belt in BS16, it is 79%. We know that there are already regional ambulance response time issues (so placing more demand in a location which the ambulance services currently struggle to service to an acceptable standard is another demonstration that Buckover is a poor choice of site).

Page 10 of 21

There is no local police station

The nearest neighbourhood police station is in Chipping Sodbury some 8 miles away which can only be reached by car. Fire Service provision is only by retained Firemen based in Thornbury and Dursley.

There are no mains services and overhead power cables run across the site

There is no mains gas, foul sewage or fibre optics in the area and routing them to an area is a costly add on expense for a development. There are overhead electricity power lines and pylons crossing the site, building under or in proximity to these is not recommended due to maintenance, safety and health reasons, diverting them is another costly expense.

The site has a history of drainage and flooding

There are a flood zones within the footprint of the Buckover site. Residents of Whitfield experience flooding during periods of heavy rain and most residents rely on the maintenance of drainage Rhines to prevent their dwellings from flooding. This situation has been exacerbated by the elevated road surface levels of the A38 and the Gloucester Road compared to the internal ground floor levels of the older cottages. Fire engines have been called out to pump away water ingress in Brinkmarsh Lane, Iron Hogg Lane, The Cornfields and the cottages along Gloucester Road over recent years. The soil type in the area is “Falfield Clay”, this is a very dense clay which holds surface water high on the ground and does not let it drain away easily. Whilst providing good nutrients for arable farming, it makes any attempt to install soakaway drainage systems problematic, hence the reliance on Rhines. Existing residents are concerned that the carefully balanced existing drainage system will be overwhelmed by the run off of any new settlement and that their properties will be placed at increased risk of flooding. The Council should also take into account that these ground conditions, combined with the risk that costly piled foundations to firmer strata below the clay will be required which will significantly increase development costs and its viability.

It is detrimental to the local ecology

The JSP fails to identify the ecological constraints of the Buckover site. Stating that there are no ecological constraints before undertaking a study is misleading. The Buckover area is a habitat for many protected and endangered species and fauna including bats, owls, grass snakes, voles, hedgehogs, toads, greater crested newts, foxes, and badgers amongst others. It is a popular stopping and foraging place for flocks of migrating birds. Deer, rabbits, foxes also rely on habitats in the area.

It affects existing Sites of Special Scientific Interest & Sites of Nature Conservation Interest

The proposals adversely affect two nationally important SSSI sites which cover 2.2 Hectares of the site. There is also a site of SNCI.

Page 11 of 21

The new settlement is too close to a proposed replacement Nuclear power station site

We question the logic of planning to locate a new permanent community of circa 8000 people within only four miles of, within sight of and downwind of the proposed site for the new nuclear power station at Oldbury. The Department for Business, Energy & Industrial Strategy guidance says that power stations should not be close to large populations for safety reasons. There are serious health and safety and emergency evacuation implications related to this site. Within a ten mile radius the air could be unsafe to breathe in the event of a major catastrophe.

For the reasons outlined above it is clear that Buckover is an unsuitable location for a new settlement. There are fundamental problems with this site present from the outset that no amount of mitigation can overcome. If the West of England Partnership still wish to pursue the new settlement option then a more sustainable and practical location which can achieve its own community identity and is not subject to the unknown timescales of major Highways England infrastructure implementation should be sought.

Our comments returned for the previous round of the JSP still stand, these called for another review of the green belt which we suggest should be expanded outwards releasing land on the inside which is closer to key facilities, existing services and infrastructure, such as the newly implemented metro bus routes and the rail network. This would prevent large developments leapfrogging over the green belt and further into open countryside. It would be a more sustainable approach as it prevents commuters to the city from travelling back and fore across the green belt adding to congestion on rural roads and pollution.

We understand the need for affordable housing in the region but in this location, there is a great risk that the high infrastructure costs and the need to provide of all key services will make affordable housing unviable at Buckover. This is proven by the recent unfortunate situation where developers at the nearby Park Farm development in Thornbury are requesting a significant reduction in the proportion of previously agreed affordable housing numbers to make their scheme viable. Furthermore, locating affordable housing in such a remote outpost of the West of England region would further restrict the movement of those people who cannot afford to buy a car or commute by car or pay expensive bus fares to travel to the city centres for work. This places an added burden and worry on those who can least cope with it.

To sum up

We are not confident that the West of England Joint Spatial Plan, Towards the Emerging Spatial Strategy document in relation housing development in Thornbury and outlying villages has been properly thought through. We believe that the proposals do not provide enough detail on the infrastructure and services required within a rural environment based

Page 12 of 21 on the level of development proposed. Our local road network is already at overcapacity at peak times and our local services are at full stretch. Any major development should take place as close as possible to a reliable transport network and major centres of employment.

Yours Sincerely,

James Carpenter

Clerk to Falfield Parish Council

Page 13 of 21

Clerk: Mrs Dawn Bramley, 1 Court Mead, Stone, FALFIELD Gloucestershire, GL13 9LF. Telephone: (01454) 261677 PARISH COUNCIL [email protected]

South Gloucestershire Council Department for Environment and Community Services PO Box 299 Strategic Planning Civic Centre High Street Kingswood Bristol BS15 0DR

30th March 2016

Dear Mr David Stockdale, Reference: PT16/0770/O Land at Heneage Farm, Moorslade Lane, Falfield, South Gloucestershire, GL12 8DJ Change of use and development of agricultural land to provide up to 115 dwellings with associated access, parking, hard/soft landscape works, public open space, and drainage, together with development of a 'Park and Share' facility for up to 100 cars (Outline) with access to be determined. All other matters reserved Falfield Parish Council has the following 10 OBJECTIONS to make regarding the above application. Size of Proposed Development There appears to be much speculation about the actual number of houses within Falfield and confusion regarding the total number of houses within the Falfield parish boundary compared to those within the settlement boundary of Falfield Village itself. Errors have been made by the applicant Cotswold Homes in their supporting statements, for example in the Planning Supporting Statement, dated February 2016, paragraph 2.3, they describe the whole parish’s population statistics as Falfield Village’s statistics. In paragraph 7.21 they inaccurately state the number of existing houses in Falfield Village as 200, which is more than double the actual figure within the village, this is misleading. As a result the figures being quoted by some residents in their consultee responses are incorrect. We therefore start the Parish Council’s response with some actual figures based on a recent door to door count to clarify the numbers involved. The parish of Falfield is a small rural parish which is located each side of the A38 stretching from the South Gloucestershire and Gloucestershire county border at Stone through Falfield, Eastwood Park and Whitfield up to Buckover and Milbury Heath. Falfield Parish has

Page 14 of 21 approximately 228 dwellings in its remit, of which 92 dwellings are located within the Falfield Village settlement boundary itself. The remainder are rural dwellings in the open countryside, of which at least 12 dwellings are known to be currently unoccupied. There are 22 potential new dwellings, already with valid planning permissions, planned for the parish which are currently under construction or pending construction imminently which are not included within the above figures. Therefore Falfield Parish is already committed to expand in size by about 10% over the next three years. The proposed development is on agricultural land adjoining the settlement boundary of Falfield Village, it is not within it. At a recent Parish Council meeting parishioners expressed that they still wish to keep the settlement boundary as it is which is in line with Falfield Parish Council’s Polices, Sites and Places response. The number of dwellings proposed is larger than the current number within Falfield Village; at 115 dwellings it represents a 125% increase on the existing size of Falfield Village and a 50% increase on the size of the whole of Falfield parish. Most of the feedback the Parish Council has received from parishioners has been to express concerns about the size of the development, which is larger than the current village itself, and will have a significant impact on the village. The addition of 115 dwellings in a single development is not appropriate and is disproportional to the existing size of the Falfield Village settlement. It will have a significant adverse and detrimental impact on its character. The village has gradually expanded over the years and has embraced varying styles of housing, however all of the previous estates have been modest in scale and have been less than a quarter of the size of what is now being proposed. The Parish Council has seen no justification as to why this amount of housing is being proposed for our parish, it is not in a particularly sustainable location, it is out of scale with the village and it is not a scheme being driven forward by our local parish community or by specific local demands. Therefore, the Parish Council must object to the proposal as it is clearly over development.

Highways This proposal for 115 dwellings and a park and share scheme is of a size and scale that will adversely impact on the local roads and Junction 14 of the M5 motorway because of the amount of vehicle movements that will be associated with the scheme. The existing agricultural field generates few vehicle trips in comparison. More vehicles will pass through Falfield as a result. The M5/A38 junction is a known “bottleneck” in this area. There are problems with traffic congestion on the B4509 for traffic crossing the motorway bridge and queuing traffic backing up onto the A38 from the motorway junction. As a result the traffic lights at the motorway junction have to be turned off at peak times to try and keep the B4509 flowing and prevent gridlock. The Parish Council is aware that Highways England, in their consultee response dated 21st March 2016, has expressed serious concerns over the existing issue of traffic queuing on the slip roads leading to Junction 14 of the M5 which leads onto the main section of motorway and has flagged this up as a significant road safety risk. The Parish Council agrees with their assessment and recommendations that junction improvements would be necessary if vehicle

Page 15 of 21 movements are to increase; however this would be costly and the Parish Council are unaware of any imminent improvement plans. The proposed site at Heneage Farm it is not a sustainable location due to poor public transport provision. The majority of its potential residents will be commuting to work by car, predominantly in the Bristol or Gloucester hubs. Major developments already approved for the nearby towns of Thornbury, Charfield, Kingswood, Cam, Stone and Sharpness will have already made the situation worse for a junction which is already operating over capacity. Therefore, the Parish Council must object to the proposal on highway safety grounds.

Access Site access is via the busy A38 or single track country lanes without any footpaths. Moorslade Lane itself is a narrow country lane and is not suitable to handle the demands of the quantity of vehicles this type of application will introduce. The widening of Moorslade Lane and the removal of the hedgerow is likely to have a significant effect on the landscape character in the vicinity and on the setting of the housing and buildings alongside it. The location of the entrance into the proposed Park and Share site, which is close to the A38 junction may hold up other traffic with the potential to back up traffic onto the A38 itself. This access is already well used by lorries and agricultural vehicles associated with the businesses and farms along Moorslade Lane. This would cause further conflict when accessing either the housing development of Park & Share. The proposed emergency access on Sundayshill Lane needs further consideration to ensure that is it not used as an alternative shortcut as there is a contradiction between making it a pedestrian and cycle only route to one which can accommodate large emergency services. Therefore, the Parish Council must object to the proposal due to site access concerns.

Flooding According to the Environment Agency, part of the site is within Flood Zone 3, this category has the highest probability of flooding. The Parish Council regularly witnesses saturated ground due to the dense impermeable “Falfield” clay ground type, flooding issues affecting this site and the road infrastructure serving it. We are concerned that this proposed new development may exasperate the situation as it relies on draining into a stream in a high risk flood zone. There is photographic evidence of recent flooding of nearby roads, gardens, fields and houses. Currently the Park and Share Site, after the recent rain, is saturated and under water. The stream running alongside the length of the proposed site regularly bursts its banks. When this area floods, the implications downstream as well as at the site are significant with the runoff affecting Moorslade Lane, Lower Stone, Rockhampton, Peddington and into Berkeley. Emergency Services have been unable to access parts of Lower Stone and cars have had to be rescued from flood water down these lanes and the surrounding road network. The effects of Climate Change have been evident with the change in weather patterns over the last 5 years as a result flooding in Moorslade Lane and Sundayshill Lane being particular bad.

Page 16 of 21

It is not clear who will maintain the attenuation ponds or the stream as any debris blockages will cause significant flooding. If the foul sewer pumping station is close to the surface water attenuation ponds it will be at risk of flooding and could result in cross contamination. The Parish Council is concerned by the proposal to locate children’s play areas in an area which floods and close to the attenuation ponds as they may be hazardous to children and encourage midges. Therefore, the Parish Council must object to the proposal on the grounds that it will be detrimental to an already problematic flood situation.

Public Transport Falfield has limited public transport provision and journey times to nearby larger town centres are lengthy. Parishioners regularly report difficulty in using public transport to go to and from any place of employment, further education, extra curriculum school activities or transport hubs including train station. The bus operators are reluctant to operate the routes through Falfield which has resulted in the bus routes being regularly being amended or stopped. This has caused a service which is unreliable, infrequent during the day and non-existent in the evenings. The A38 and B4509 are already very busy roads and parishioners have to cross them in the vicinity of a congested junction to catch a bus to school or elsewhere. If the traffic levels increase, due to this development the parishioners will be put at further risk. Therefore, the Parish Council must object to the proposal on the grounds that there is inadequate public transport to sustain this development.

Amenities Falfield Village has some useful facilities, including a small shop, post office, church, public house and village hall. There are few opportunities for local employment so most parishioners travel outside of the parish to their workplaces, predominantly by car. There is no school or preschool provision within the parish. Tortworth Primary School is the nearest primary school and preschool. It is not physically possible to walk to this school due to a lack of footpaths and road safety issues such as the need to cross the busy M5 motorway junction 14. Given the steep incline of the B4509, the narrowness of the lanes and the speed of the traffic coming off the motorway cycling to school is not an option especially not for children of primary age. All journeys to this school rely on vehicular transport. Castle School is the nearest secondary school but the route to school is classed as a hazardous route, so all journeys to this school rely on vehicular transport. Access to Healthcare services is limited and again relies on vehicular transport. The demand for these services is already increasing due to the increase in the population in the area as a result of other major developments. Therefore, the Parish Council must object to the proposal on the grounds that it is not a sustainable location.

Services There is no mains sewer currently serving dwellings in the parish. Most dwellings are reliant on their own sewage treatment plants or the HMP Eastwood Park network where houses are on Home Office Land

Page 17 of 21

The submitted Foul Drainage Assessment, dated February 2016, states an intention to connect into the existing foul network serving HMP Eastwood Park. This is a recent link connecting HMP Eastwood Park’s sewer to HMP Leyhill Sewerage Treatment Works (STW) resulting both from a need to expand the women’s prison and of dire foul drainage problems for the prison and dwellings on HMP’s own land in the Falfield village. The submitted information indicates that Wessex Water have not confirmed to the developer that a sewer connection for the proposed housing is feasible however, so this proposal is premature. An alternative fall-back foul drainage solution has not yet been tabled but would not be straightforward for a development of 115 houses in a field with heavy “Falfield” Clay, poor drainage and flooding. Should the connection to Leyhill STW be accepted by Wessex Water, Falfield Parish Council reiterates Tortworth Estates response, dated 29th March 2016 raising serious concerns about the resulting environmental impacts on Tortworth Brook downstream of the STW which also runs through our parish and into the Little River Avon and beyond and we would expect effective mitigation measures. There is no mains gas supply serving Falfield parish. We have safety concerns over the proposed presence of the buried LPG gas storage tanks and their proposed location under the allotment car park. We also note that the Environment agency requested a bund around the tanks against flooding which is incomparable with its proposed location. Despite recent upgrades most of Falfield parish, including the village on this side of the A38 still does not have access to superfast broadband and band width speed is poor. Therefore, the Parish Council must object to the proposal on the grounds that services available are limited and there are flaws in the strategy.

Landscape There are many views towards this site which will be affected, these being residents whose gardens adjoin the site, visitors passing through the village along the A38 and from elevated positions to the north. The indicative drawings submitted show some suggestions of landscape buffer planting on some boundaries however there is some concern that this planting now appears to be significantly reduced from what was tabled at the community consultation display to the parish. There are also contradictions between a number of the plans and the landscape strategy plan submitted which need to be rectified as the supporting documents use different base plans. The ION Acoustics Residential Planning Noise Assessment, dated 23rd March 2016 advises that mitigation measures will be required to address the impact of excessive noise levels from the nearby A38 road and that some sound insulation measures will be required to south eastern gardens facing the A38, in light of this the addition of acoustic fencing, walls or earth bunding is recommended by the consultant. Again there is a contradiction with the master plan as this is not illustrated. The Parish Council have concerns about the visual impact of this acoustic screening, as this sort of enclosure is not typical of the local landscape and may also result in the separating of the existing and proposed new community. The Parish Council has concerns about how the landscaping, footpath and cycleway will be arranged around the historical horse pool, which is a designated archaeological site alongside the A38 and how this integrates with the acoustic buffers.

Page 18 of 21

The Parish Council also has concerns that the Park and Share is located on top of a designated archaeological site known as Turnpike Cottage which is not reflected in the master plan. Therefore, the Parish Council must object to the proposal on the grounds that the landscape proposal is unresolved.

Open Spaces It is not clear whether the developer intends to provide the outdoor facilities illustrated, or whether they are leaving it for others to sort out at a future date. There has been no discussion with Falfield Parish Council over who will adopt or maintain the open spaces for the lifetime of the development e.g. cutting the grass, safety inspections. Will this be done by a resident’s management company, by a separate maintenance company, or by South Gloucestershire Council? There is currently no capacity within the Parish Council to take on these areas. Parishioners have raised concern that the proposed play areas are within a part of the site which floods, that the play areas are too close to houses and that the communal areas may generate anti-social behaviour particularly in close proximity to an unsupervised Park and Share car park. Therefore, the Parish Council must object to the proposal on the grounds that unresolved financial, location and maintenance issues relating to open spaces.

Park and Share Facility The Park and Share facility for 100 cars offers little benefit to the residents of Falfield, our parishioners have no need to use it and it is likely to have a more negative than positive impact on the parish. The Parish Council has serious concerns about the potential for anti-social behaviour occurring in this quiet part of the parish. The site is not positioned where there is natural surveillance. No information on how it will be policed and by who has been provided or discussed with the parish. There are significant issues raised in the Avon and Somerset Constabulary Crime Prevention Design Advisors report, dated 21st March 2016 which are of serious concern to the Parish Council. The Park and Share’s remote location will not encourage commuters to use it as users may feel their cars will not be safe there or feel safe in person particularly at night. Given a choice commuters will probably still prefer to park in more visible locations such as outside parishioners houses near the junction, in the busy lay-by off Tortworth Hill or on the A38. There is no gate proposed to lock the Park and Share facility at night to prevent it becoming a venue for anti-social use after hours by a variety of groups, legally or not, be they boy racers, travellers or rogue traders etc. These are not activities we want to encourage in our small quiet rural parish. There is currently just one house near the proposed Park and Share site positioned on the opposite side of Moorslade Lane which may end up bearing the brunt of reporting concerns about the facility which is unfair and potentially intimidating for them. Southbound traffic from the M5 would have to navigate 3 sets of lights to get to the Park and share facility and then another 3 sets of lights to re-join the M5 motorway. A peak times this

Page 19 of 21 could add half an hour to the journey time and would discourage people from using it or result in commuters waiting at the M5 junction slip roads for their lift, having walked from the Park and Share to avoid the detour. The Parish Council feels that South Gloucestershire Council should explore other sites for locating a Park and Share facility, including on the eastern side of the Junction 14 motorway junction before the southbound M5 motorway junction where most demand is already displayed. Tortworth Estate has also offered land to South Gloucestershire Council in this location for a Park and Share. A Park and Share development here would complement the existing highway maintenance compound by the B4509. Therefore, the Parish Council must object to the proposal on the grounds that the Park and Share offers no benefit to the parish and will encourage anti-social behaviour in the area.

Yours Sincerely,

Clerk to Parish Council For and on behalf of Falfield Parish Council

Page 20 of 21

TOWN AND COUNTRY PLANNING ACT 1990 REFUSAL OF OUTLINE PERMISSION FOR DEVELOPMENT APP REF: PT16/0770/O DATE VALID: 25th February 2016 DECISION DATE: 13th February 2017 PARISH: Falfield Parish Council Aspect360 Ltd 45 Oakfield Road Clifton Bristol BS8 2AX NOTICE OF DECISION South Gloucestershire Council in pursuance of powers under the above mentioned Act hereby REFUSE to permit: APPLICATION NO: PT16/0770/O DESCRIPTION OF DEVELOPMENT: Change of use and development of agricultural land to provide up to 115 dwellings with associated access, parking, hard/soft landscape works, public open space, and drainage, together with development of a 'Park and Share' facility for up to 100 cars (Outline) with access to be determined. All other matters reserved

APPLICANT: Mr M Glen Cotswold Homes Ltd

LOCATION: Land At Heneage Farm Moorslade Lane Falfield Wotton Under Edge South Gloucestershire In accordance with the application and accompanying plans, for the following reasons: REFUSAL REASONS 1. The proposed development is unsustainable due to the location of the site and its distance to available services, facilities and employment and the high reliance on the use of the private motor car. As such the adverse impact of granting planning permission would significantly and demonstrably outweigh the benefits contrary to Policy CS5 and CS34 of the South Gloucestershire Local Plan Core Strategy 2013 and the provisions of the paragraph 14 of the National Planning Policy Framework.

Page 21 of 21