Matter 6: Cinderford and Ruspidge

Forest of Dean District Council ‘s (FoDDC) response re Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016). Matter 6: Cinderford and Ruspidge

Forest of Dean District Council’s (FoDDC) Response Matter 6: Cinderford and Ruspidge

Re: Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016)

Forest of Dean District Council ‘s (FoDDC) response re Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016). Matter 6: Cinderford and Ruspidge

The following is a response to Matter 6 from the FoDDC to the Inspector’s Matters and Issues published in December 2015. It addresses the points raised but needs to be read in conjunction with the Allocations Plan as submitted, the published responses to the various representations, the published documents, and the Council’s responses to the Inspector’s initial questions (November 2015). References are added below to the most relevant documents in relation to the Matters as listed. Matter 6: Cinderford and Ruspidge 6.1. Is there evidence that the AP’s The FoDDC has evidence that these sites are capable of being allocation for housing on the developed but does not consider them to necessarily be wholly following sites, including as part of available in the first five year period. The comments below set mixed development, is not justified, out the current position in respect of sites which are required to sustainable, viable, available or provide the identified housing needs throughout the plan period. deliverable? Station Street (Policy AP 33) This is a complex site allocated in total for about 150 dwellings. It comprises a large area of former industry now partially cleared and an undeveloped area, together with a former Inn. The previous uses have ceased and there is a need to redevelop the site.

AP33 is a comprehensive allocation and the site is bounded by housing or highways. The site is a redevelopment area, the bulk in a single ownership. It is largely vacant, and part cleared. Following the recession and the refusal of consent for a supermarket, at the time when major operators wished to expand, it is considered available by the owner. A portion of the site is able to be developed inside five years but the majority is more likely to come forward later. The cleared element, the separate undeveloped area adjoining Valley Rd and the former Railway Inn are considered to be potentially available within five years for housing completions and an element of the housing yield from these parts of the larger allocation is included in estimated five year supply. In response to the annual survey of sites the owner of the bulk of the land (capacity 130 approx) considered that site able to deliver completions within five years.

If the government’s “brownfield” aspirations are realised the allocated site, AP33, is one site that will be likely to be deemed to have a planning permission. The nearest similar site within Cinderford is nearing completion with the delivery of 92 dwellings. This was part undeveloped and part occupied by an abattoir.

Cinderford Football Club This site is an allocation not relied on in the current five year (Policy AP 34) assessment. It is however included as an allocation for about 80 dwellings and is therefore considered deliverable. This is in recognition of the need for the football club to relocate. The football club land is in part owned by a local house builder. The remainder and majority of the site is allocated for open space and this can provide an alternative site for the club, although it

Forest of Dean District Council ‘s (FoDDC) response re Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016). Matter 6: Cinderford and Ruspidge

could exercise other options.

A representation on behalf of the school (APPV392) seeks a more mixed form of development to include land north of Causeway Rd within the area that could be developed for housing. The same ownership does include land south of the road and a part of this lies within the area identified a suitable for housing. This and the redevelopment of the entire football club site is considered appropriate and able to be developed. The policy as worded supports the relocation of the football club in a specific area and is the preferred position. An alternative would be able to be considered if the needs of the club were met on a convenient site elsewhere. The required alternative provision would be expected to be available as needed by the club.

Valley Road (Policy AP 36) This site is inset into the industrial area, Forest Vale. It is part of an allocation for housing and employment. The owner supports the allocation and an outline planning application is understood to be in preparation following a pre application consultation round (APPV6). The consultation included representations from the owner seeking a change in the “tie” in the policy to the construction of new employment space. This was originally set at 2500m2 but was reduced to 1000m2. The owner of this site has other employment units in Cinderford some of which are managed and let. Delivery of the employment floorspace would be likely to be by this route. The adjoining land is not in intensive use for employment, and most of the edge of the housing element would be redeveloped under the policy or is open land, housing or road. It is considered and agreed by the owner that the redevelopment of the site for housing is a realistic option.

If the government’s “brownfield” aspirations are realised it is one site that will be likely to be deemed to have a planning permission.

If such evidence exists what Alternatives if submitted as part of the plan process or as part of alternatives are available and have the SHLAA have been considered. Although some alternative they been satisfactorily considered sites have been proposed in Cinderford they are not considered by the Council? to be suitable even if there is a need for them. The responses to the various sites that were suggested for development are appended to the statement of consultation http://www.fdean.gov.uk/nqcontent.cfm?a_id=7872&tt=graphic.

6.2. In particular, Policy AP34 See 6.1 above. requires that the Cinderford Town FC move to a new location before the housing can be delivered. Is there an indication of the likelihood of the football club making that move?

Forest of Dean District Council ‘s (FoDDC) response re Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016). Matter 6: Cinderford and Ruspidge

6.3. Policy AP36 requires that See 6.1 above. 1000m2 of employment space must be completed before the first house is occupied. What will be the effect on the deliverability of the housing element?

6.4. Is the AP’s approach to The site overall is part occupied by derelict or semi derelict development in the town centre buildings and the only significant built feature is the former Inn. (Policies AP 31, 32, 33) justified, In developing the wider site it is considered that the retention of sustainable and consistent with CS this building would provide a useful key building and a link to the and national policy? Is there an past. It was built between about 1880 and 1903. adopted programme of planned environmental improvements (Policy AP 31)? What is the justification for the requirement to retain the Railway Inn (Policy AP 33)?

6.5 Is the AP’s approach to the The proposal referred to is for a supermarket on land at Forest provision of land for employment Vale. In its original form, it was 4645m2 gross and was permitted generating uses (Policies AP 35, 36) in outline and detailed form by the Council. Subsequent legal justified, sustainable and consistent challenges have quashed the decision. It is likely that it will be re with CS and national policy? Should considered shortly. Policy AP 35 include an allocation for the approved superstore? The land on which the planned superstore is proposed is within an area protected for employment generating uses. Retail use would fall within this definition (the glossary of the AP is incomplete and should reflect paragraph 6.47 of the CS and the CS Inspector's report). Reference is also contained in the AP to a broader range of uses (2.16) and the term “employment generating uses” is employed throughout. It is considered that subject to the judgement that any impacts on the town centre are acceptable then the site may be considered for retail. The situation referred to in the AP was correct at the time of writing but there is now no permission but an application to be re considered following legal action.

There is therefore considered to be no need to make a specific allocation for the development at Cinderford. The development as proposed has the support of the Council and is as referred to in the AP regarded as a commitment (5.20).

Allocations are proposed in the towns in accord with the identified needs which stem from the retail studies of 2008 and 2011 which supported the CS. No major allocation is able to be made in Cinderford town centre as land is not available. The committed development referred to above is out of centre and

Forest of Dean District Council ‘s (FoDDC) response re Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016). Matter 6: Cinderford and Ruspidge

reflects the absence of a town centre or edge of centre opportunity.

The needs of the four towns are referred to in the CS and the main allocations along with the other town centre policies provide for a mix of uses intended to encourage activity in the towns. The town centre allocations made in the AP are able to meet the retail needs identified with the exception of the need for additional convenience space considered to be required in Cinderford.

The Council’s response to the Inspector’s initial questions is available as below: FoDDC Response to Inspectors Questions October 2015 Retail and Town Centres

6.6. Is the AP’s approach to the The policy is simply an expression of the AP's wish to protection of the Linear Park (Policy protect the LP for informal recreational use which with the AP 37) justified, sustainable and implementation of the published suggested change will consistent with CS and national acknowledge its importance for wildlife. It is compatible policy? with the NPPF in for example delivering (or in this case safeguarding) recreational facilities.

AP 37 policy area stretches for 2km from Ruspidge Halt in the south to edge of the Cinderford Northern Quarter Area Action Plan area in the north. The Council acknowledged the ecological importance of the area covered by the policy.

The Council proposes an amendment to the Cinderford Chapter in the Key Issues box for Cinderford; add under “sustainable development” point three…”To protect and enhance the biodiversity of the area in recognition of its importance”

The Council also proposes the following changes:

“AP 37. The Linear park as identified on the policies map is an important local recreational and natural resource which shall be protected from development incompatible with its use for informal recreation.”

After “green infrastructure” in 5.24, add “ The Linear park is a complex area of considerable importance for nature conservation”

Forest of Dean District Council ‘s (FoDDC) response re Inspector’s Matters and Issues in relation to the Allocations Plan Examination (January 2016). Matter 6: Cinderford and Ruspidge

Key to abbreviations

AA Appropriate Assessment AONB Area of Outstanding Natural Beauty AP Allocations Plan, policies are AP… CA Conservation Area (built environment) CIL Community Infrastructure Levy CNQAAP Cinderford Northern Quarter Area Action Plan CROW Countryside and rights of Way (Act) CS Core Strategy, Policies are CSP… DSB defined settlement boundary (dsb) EA Environment Agency FoD Forest of Dean FoDD Forest of Dean District FoDDC Forest of Dean District Council GCC Gloucestershire County Council GI Green Infrastructure HE Historic England HMA Housing Market Area, (Gloucestershire) HRA Habitats Regulations Assessment IDP Infrastructure Delivery Plan IOA Important Open Area (Plan designation) LCA Landscape Character Assessment LDF Local Development Framework LPA Local Planning Authority LSPD Landscape Supplementary Planning Document NDP Neighbourhood Development Plan NE Natural England NPPF National Planning Policy Framework NPPG National Planning Policy Guidance OAN Objectively Assessed Need (for housing) S106 Agreement- Section 106 of Town and Country Planning Act SA Sustainability Appraisal SAC Special Area of Conservation SHMA Strategic Housing market Assessment SPA Special Protection Area (environmental) SSSI Site of Special Scientific Interest (nature conservation) STW Severn Trent Water, water company WW Welsh Water/ Dwr Cymru water company