Forest of Dean - Local Development Framework

Allocations Plan Pre-Publication Draft – July 2014

Land at Beachley Road, Sedbury /

September 2014

Forest of Dean - Local Development Framework

Allocations Plan Pre-Publication Draft – July 2014

Land at Beachley Road, Sedbury / Tutshill

Project Ref: W:\17000\17109\A5 W:\17000\17109\A5 Reports & Reports & Graphics\Reports Graphics\Reports Status: Draft Final Issue/Rev: 01 02 Date: 9th September 2014 15th September 2014 Prepared by: Cai Parry Cai Parry Checked by: Pete Sulley Pete Sulley

Barton Willmore Greyfriars House Greyfriars Road CF10 3AL

Tel: 029 2066 0910 Ref: 17109/A5/CP/gp Fax: 029 2066 0911 Date: September 2014 E-mail: [email protected]

COPYRIGHT

The contents of this document must not be copied or reproduced in whole or in part without the written consent of Barton Willmore Planning LLP.

All Barton Willmore stationery is produced using recycled or FSC paper and vegetable oil based inks. CONTENTS PAGE

1.0 Introduction 1

2.0 Site and Surroundings 5

3.0 Compliance with NPPF and PPG 7

4.0 Land at Beachley Road, Sedbury 16

5.0 Conclusions 23

APPENDICES

APPENDIX 1 Site Location Plan APPENDIX 2 Illustrative Masterplan APPENDIX 3 Proposed Allocations Plan extract APPENDIX 4 Assessment of sites contained within Council’s Housing Land Supply APPENDIX 5 Landscape and Visual Appraisal Key Facts Sheet: Land adjoining A48 and Bigstone Meadow, Tutshill APPENDIX 6 Allocations Plan Site Appraisal - Land adjoining A48 and Bigstone Meadow, Tutshill APPENDIX 7 Landscape and Visual Appraisal Key Facts Sheet: Land at The Elms, Sedbury Lane, Sedbury APPENDIX 8 Allocations Plan Site Appraisal - Land at The Elms, Sedbury Lane, Sedbury APPENDIX 9 Allocations Plan Site Appraisal - Land at Beachley Road, Sedbury

Introduction

1.0 INTRODUCTION

1.1 These representations have been prepared by Barton Willmore on behalf of Barratt Homes. These representations are in relation to the Allocations Plan Pre Publication Draft, 21st July 2014 (hereinafter referred to as the ‘Allocations Plan’) and they set out the merits of allocating Land at Beachley Road, Sedbury (hereinafter referred to as the ‘site’) for residential development for approximately 110 homes, in the Allocations Plan. Appendix 1 contains a Site Location Plan and Appendix 2 contains an Illustrative Masterplan demonstrating how up to 110 homes could be delivered.

1.2 This Illustrative Masterplan was submitted with an outline planning application for “up to 110 homes (with all matters reserved except for access), public open space, landscaping, highways improvements and associated engineering works” (P1792/13/OUT which was submitted in December 2013). Officers recommended approval of the scheme to Planning Committee in April 2014 and May 2014, with no technical objections raised, subject to conditions and a Section 106 Agreement which Barratt Homes finds acceptable. Notwithstanding the above, Members resolved to refuse the planning application, as set out below within the sole reason for refusal:

“The development of this prominent site on high ground, unallocated for development and outside the recognised confines of the settlement, would represent a substantial extension of the built up area and a significant visual intrusion into the open countryside, and severely diminishing its value as a green wedge separating the two parts of the settlement. These adverse impacts would significantly and demonstrably outweigh the benefits arising from the proposed development, including any contribution to the five year land supply, and result in development contrary to Policies CSP.1, CSP.4 and CSP.5 of the Core Strategy.”

1.3 Barratt Homes has lodged an appeal against the Council’s decision (Appeal Ref: APP/P1615/A/14/2220590) and this is due to commence on the 30th September 2014. These representations therefore also effectively summarise Barratt Homes’ position in relation to the above appeal.

1.4 In addition, the site that is subject to these representations was proposed to be allocated for residential development of approximately 110 homes by Officers within the Allocations Plan, and this was accepted by Members at Cabinet in April 2013 and Full Council in May 2013 (proposed Allocations Plan extract attached at Appendix 3). The

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proposed allocation has subsequently been removed from the Draft Allocations Plan as a result of the Planning Committee’s refusal in May 2014, and has been replaced by two alternative sites (AP89 Land adjoining A48 and Bigstone Meadow, Tutshill and AP90 Land at The Elms, Sedbury Lane, Sedbury) which Officers have previously considered to be not as appropriate as Land at Beachley Road. This will be demonstrated later in these representations.

1.5 Finally, the Forest of Dean Council adopted its Core Strategy in February 2012. The Core Strategy sets out the need to deliver 6,200 homes over the Plan period 2006 to 2026. This figure was based upon Appendix A (ii) of the Draft South West Regional Spatial Strategy Examination in Public Panel Report (April 2007) (Draft SWRSS EIP) which identified that the Forest of Dean needed to deliver 6,200 homes during the RSS Plan period 2006 – 2026. It is evident from this RSS Panel Report that the 2003 DCLG household projections identified a need for 8,272 dwellings over the Plan period from 2006 to 2026. It is evident therefore that the figure of 6,200 is a constrained requirement figure, which is contrary to the NPPG and of significance in light of the Hunston Court case and the abolition of the RS (and draft).

1.6 Put simply, the figure of 6,200 homes is therefore not based upon objectively assessed needs, as required by paragraph 47 of the NPPF. The Core Strategy, which was prepared before the publication of the NPPF, is therefore not in parallel with the NPPF in this regard. Specifically, the Core Strategy is not based upon the presumption in favour of sustainable development, as set out within paragraph 14 of the NPPF.

1.7 The Core Strategy identifies the need for “about 111” new homes at Sedbury/Tutshill under Policy CSP 5 throughout the Plan period 2006 - 2026. It must be noted that “about 111” homes is obviously an approximate figure. Moreover, it is a figure identified well before the publication of the NPPF and in particular the instruction in paragraph 47 of the NPPF seeks “To boost significantly the supply of housing…” and paragraph 4 (Reference ID: 2a-004-20140306) of the PPG, which seeks to ensure that “Plan makers should not apply constraints to the overall assessment of need”. The need to boost significantly the supply of housing applies to both market and affordable housing.

1.8 Therefore, it does not follow that either 6,200 homes or “about 111” homes are maximum figures, i.e. such housing figures are not ceilings and the imposition of such “ceilings” would be inconsistent with the NPPF.

1.9 These representations therefore need to be considered within the context of all of the above matters.

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1.10 This document is therefore set out as follows:

• Section 1.0 introduces these representations, setting out the most recent planning history on the site and the current development plan position, as contained within the Forest of Dean Core Strategy (adopted February 2012) and showing regard to the National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG); • Section 2.0 briefly describes the site and surroundings, including the status of the settlement of Tutshill/Sedbury within the Core Strategy, to provide a context within which to consider these representations to the Allocations Plan; • Section 3.0 considers the NPPF and legislation that the Allocations Plan is required to comply with before considering a number of the proposed allocations within the Allocations Plan (based upon the more detailed analysis contained within Appendix 4 and with a particular emphasis on the two alternative proposed allocations within Sedbury/Tutshill), against the NPPF (most notably paragraphs 14, 47 (including footnote 11) and 182) and PPG (most notably paragraph 31 of the ‘Housing and Economic Land Availability Assessment’ section); • Section 4.0 then turns to assess Land at Beachley Road, Sedbury; and • Section 5.0 provides conclusions to the above sections, and demonstrates why the Allocations Plan is not sound and therefore fails the tests set out within paragraph 182 of the NPPF.

1.11 Based on the above, these representations set out how the Allocations Plan is not sound in accordance with paragraph 182 of the NPPF and that Land at Beachley Road should be allocated for residential development in order for the Plan to be considered sound, in accordance with the key policies of the National Planning Policy Framework.

1.12 In particular, it will be demonstrated that the Allocations Plan does not provide a robust housing trajectory to meet the tests set out in paragraph 47 over the different periods, and therefore the Plan is not sound.

1.13 In addition, robust, up to date evidence has not informed the allocations nor has any robust, up to date evidence been provided to demonstrate that the allocations will be delivered over the Plan period, particularly in the first five years. The allocations are therefore not effective in accordance with paragraph 182 of the NPPF.

1.14 Further, the allocations are not deliverable in accordance with footnote 11 of the NPPF, and the Plan is therefore not sound for these reasons.

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1.15 The allocations have not been based upon the Council’s own evidence base, particularly in relation to the proposed new ‘alternative’ residential allocations in Sedbury/Tutshill, therefore the allocations are not justified in accordance with paragraph 182 of the NPPF. The Plan is therefore not sound for these reasons.

1.16 Additionally, the Plan is not consistent with national policy in that it doesn’t seek to boost significantly the supply of housing, in accordance with paragraph 47 of the NPPF, not does it provide a robust trajectory for the delivery of housing, also as required by paragraph 47.

1.17 Finally, the proposed allocations do not include Land at Beachley Road, Sedbury, which is a site that conforms to the presumption in favour of sustainable development in accordance with paragraph 14 of the NPPF. The Plan is therefore not sound as it is not consistent with national policy as required by paragraph 182 of the NPPF.

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2.0 SITE AND SURROUNDINGS

2.1 Within the Forest of Dean District Council Core Strategy, Tutshill and Sedbury together are considered to be one settlement. Therefore, whilst they have historically evolved as two settlements, for the purposes of the Core Strategy they are considered to be one settlement. The combined settlement of Tutshill/Sedbury is designated as a Major Village in the settlement hierarchy within the Core Strategy.

2.2 The site measures 4.83ha. The site lies outside, but abutting, the settlement boundary of Sedbury. The B4228 (Sedbury Link Road) lies to the west and the A48 and to railway line tunnel lie to the north. Wyedean Secondary School and its grounds lie to the south and an open field forms the eastern boundary, with Sedbury Lane and Sedbury Farm beyond.

2.3 The combined settlement of Tutshill and Sedbury has a population of approximately 4,500, as set out within the Core Strategy. This makes the settlement the fifth largest settlement within Forest of Dean behind Cinderford (approx. 35km from Sedbury/Tutshill), Coleford (approx. 21km), Lydney (approx. 14 km) and Newent (approx. 53 km).

2.4 Residential development and Offa’s Mead Academy lie to the west/ south west of the Sedbury Link Road/ Beachley Road and further residential development lies to the north of the A48, within Tutshill. Further residential development lies to the south of Wyedean School, and the Grahamstown Road Employment Area lies to the east of the school, south of the Appeal Site. Open fields lie further to the east which extend to the estuary.

2.5 A parade of shops is located on Beachley Road, which includes a convenience store, Post Office, Newsagent, Butcher, Doctor’s Surgery, Pharmacy, Hairdresser and Drapery Store. The Village Inn Public House is located on Beachley Road. A Place of Worship is located on Grahamstown Road. A fish and chip shop and the Sedbury and Beachley Village Hall are located on King Alfred’s Road. A further primary school (Tutshill Church of School) is located within Tutshill, approximately 1.5km away.

2.6 The separates Tutshill and Sedbury from Chepstow, which lies approximately 1km to the west of the site. Chepstow is identified within the Local Development Plan (LDP) as one of three Main Towns within the county. Services and facilities within Chepstow include a high street, Tesco Superstore and Chepstow railway station. The Core Strategy confirms in paragraph 3.28 that Sedbury/Tutshill is

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recognised as being “…physically and functionally linked to Chepstow, a town of about 11,000 inhabitants”.

2.7 The site is predominately bounded by hedgerows with occasional hedgerow trees and an oak tree is located towards the north western corner. It consists of two arable fields lying between approximately 34m AOD and 42m AOD.

2.8 Public Right of Way FTM/83/1 runs along the northern boundary of the site, from the Sedbury Link Road to Sedbury Lane; this links with FTM/84/1 on the northern side of Sedbury Lane as well as FTM/97/1 and FTM/99/1 to the east and south of Sedbury Lane. The Offa’s Dyke National Trail lies approximately 250m from the site and can be accessed through The Martins along FTM/83/1.

2.9 The nearest bus stops to the site are located on Beachley Road, approximately 200m from the nearest point of the site to the north (towards Tutshill) and to the south outside the two schools. These bus stops comprise signed posts and no bus shelters.

2.10 The above confirms that Sedbury/Tutshill is a sustainable location for residential development given the following characteristics:

• Proximity to services and facilities within Sedbury, in particular proximity to Wyedean Secondary School and Offa’s Mead Academy; • Proximity to bus stops and Chepstow railway station; • Local footpath and public right of way network; • Very close proximity to Chepstow, and its town centre; the town benefits from a wide range of services and facilities.

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3.0 COMPLIANCE WITH THE NPPF AND PPG

The National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG)

3.1 This section of the representations sets out whether the Allocations Plan complies with the NPPF and PPG, with a particular emphasis on the following sections of the NPPF and PPG, and includes a summary of a number of the proposed residential allocations.

3.2 From the outset, it must be considered whether the Allocations Plan is sound in accordance with paragraph 182 of the NPPF. This states that:

“The Local Plan will be examined by an independent inspector whose role is to assess whether the plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is sound. A local planning authority should submit a plan for examination which it considers is “sound” – namely that it is:

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.”

3.3 Secondly, paragraph 14 of the NPPF, and in particular the plan-making element, needs to be considered. This states that:

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“At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan- making and decision-taking.

For plan- making this means that: • Local planning authorities should positively seek opportunities to meet the development needs of the area; • Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless: - Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or - Specific policies in this Framework indicate development should be restricted.”

3.4 It must be noted the Core Strategy has already been adopted (February 2012 i.e. before the publication of the NPPF), in the anticipation that an Allocations Plan would be forthcoming to provide more ‘development management’ policies, and that the Allocations Plan therefore forms part of the Local Plan. The Allocations Plan is therefore a Development Plan Document and, for the purposes of paragraph 182, comprises a Local Plan. Consequently, the tests set out in paragraphs 14 and 182 of the NPPF still apply, and must be addressed in context.

3.5 Thirdly, the requirements of paragraph 47 of the NPPF – “To boost significantly the supply of housing” and that the “Local Plan meets the full, objectively assessed needs for market and affordable housing” – need to be shown due consideration in light of the fact that the Core Strategy was adopted prior to the NPPF.

3.6 Footnote 11 of the NPPF provides further guidance on what constitutes a deliverable site, and states that:

“To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable.”

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3.7 Paragraph 31 of the ‘Housing and Economic Land Availability Assessment’ section of the PPG states that:

“Local planning authorities will need to provide robust, up to date evidence to support the deliverability of sites, ensuring that their judgements on deliverability are clearly and transparently set out.”

Allocations Plan

Duty to cooperate

3.8 Firstly, before the content of the Allocations Plan is assessed, the first test of paragraph 182, and by extension Section 110 of the Localism Act 2011, needs to be considered. The Localism Act introduced the requirement of the ‘duty to cooperate’. This requires local planning authorities to cooperate with certain bodies when preparing development plan documents.

3.9 It is not evident from the Allocations Plan, the Sustainability Appraisal or any of the evidence base documents for the Allocations Plan that the Forest of Dean has met its duty to cooperate in accordance with Section 110 of the Localism Act. It therefore appears that the plan has not been prepared in a proper legal and procedural manner in this regard. If this is the case, then the plan is fundamentally unsound on this matter alone and it fails the first test of paragraph 182 of the NPPF.

Allocation Plan Policies

3.10 The Allocations Plan includes a number of policies to guide how and where development should be delivered within the Forest of Dean over the Plan period to 2026, as well as setting out areas of protection and other development management style policies. These representations focus on the policies that propose residential development.

Policy AP 1 – Sustainable Development

3.11 Barratt Homes supports the first sentence of Policy AP 1 – ‘Sustainable Development’ insofar as it states that the primary considerations against which planning applications will be assessed are whether or not the proposed development “…is sustainable with the overall aim of improving the economic, social and environmental conditions of the area” – that proposed development is in accordance with the ‘golden thread’ of the presumption in favour of sustainable development (paragraph 14 of the NPPF) and the

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economic, social and environmental role of the planning system (paragraph 7 of the NPPF).

3.12 The current drafting of Policy AP 1 separates these requirements from the following sentence which refers to specific allocations. It is crucial that this distinction remains. The overarching theme of the NPPF is to deliver sustainable development. i.e. a proposed development does not need to be subject to an allocation within a Local Plan.

3.13 To intrinsically link these two elements of Policy AP 1 would, erroneously, marry two different strands of decision-taking – a) the wider ‘sustainable development’ aspect, and b) the narrower ‘Local Plan allocation’ aspect. These two elements of Policy AP 1 therefore need to remain discrete.

Proposed Housing Allocations

3.14 Firstly, there is no trajectory contained within the Allocations Plan setting out the Council’s consideration of how many homes will be delivered per annum over the remainder of the Plan period to 2026 or, more importantly, how many homes will be delivered over the next five year period.

3.15 In terms of the proposed housing allocations and the delivery of housing, paragraph 2.10 of the Allocations Plan introduces the NPPF requirement for a local planning authority to demonstrate a five year housing land supply of deliverable sites, with an appropriate buffer of 5% or 20% to “ensure choice and competition in the market for land”. The Forest of Dean considers itself to be a “20%” authority because of persistent under delivery in the past, evidenced by the fact that in the period 1991/92 to 2013/14 (a period of 23 years), the Council has met its annual housing requirement only 4 times (Source Forest of Dean Annual Monitoring Reports 2006 and 2012). This is a shocking statistic.

3.16 Paragraph 2.11 of the Allocations Plan then simply leaps from the scene setting and requirements contained within the preceding paragraph 2.10 to state that “The housing provision made in the AP is sufficient to meet the present five year requirement and the overall need for the plan period”.

3.17 Given that there is no trajectory proposed, this is a major failing and does not demonstrate that the allocations are effective and deliverable, particularly over the next five years. This is especially pertinent given that the need for housing is now, as evidenced by the Council’s persistent under delivery of housing over a period of nearly a quarter of a century.

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3.18 Whilst the site specific policies which follow (many of which are addressed in detail in Appendix 4 to these representations) offer an assessment of the sites proposed to be allocated for residential development, there does not appear to be any “robust, up to date evidence to support the deliverability of sites” in accordance with the requirements of Footnote 11 and the NPPG. The Sustainability Appraisal that accompanies the Allocations Plan also does not offer any specific details regarding the deliverability of the sites in accordance with footnote 11.

3.19 Therefore, the Council’s judgements on deliverability are not “clearly and transparently set out” and as such do not accord with footnote 11 of the NPPF or paragraph 31 of the ‘Housing and Economic Land Availability Assessment’ section of the PPG.

3.20 No robust, up to date evidence has been used to inform the deliverability of many of the proposed allocations, as demonstrated in Appendix 4 of these representations. The proposed allocations are therefore not effective and therefore fail the subsequent test within paragraph 182 of the NPPF.

Site Specific Proposed Residential Allocations

3.21 As set out above, Barratt Homes does not consider that the proposed housing allocations are based upon up to date, robust evidence, particularly in relation to deliverability. This is dealt with in more detail in Appendix 4 where all of the proposed residential allocations are critically assessed (and summarised in Table 4.1 in Appendix 4); indeed this assessment is contained within the Proof of Evidence that was submitted to The Planning Inspectorate in relation to the aforementioned Section 78 appeal for the site (APP/P1615/A/14/2220590).

3.22 However, the below paragraphs are a general summary of that assessment, with references to some of the key sites.

3.23 Further, it is considered prudent to critically assess the two new ‘alternative’ sites that have now been proposed within Sedbury/Tutshill now that Land at Beachley Road is no longer included given the decision at Planning Committee, despite the fact that Members approved its draft allocation at Cabinet in April 2013 and at Full Council in May 2013, and that Officers recommended approval of the outline planning application given that there were no technical objections, subject to conditions and Section 106 Agreements (which have subsequently been signed in relation to the Section 78 appeal). These two sites are therefore addressed in more detail than the other proposed residential allocations below.

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3.24 A significant number of the proposed allocations are historic sites which have been ‘on the radar’ for a number of years. This is evidenced by the fact that many have either been allocated since the 2005 Local Plan (some 9 years ago), such as AP 61 Poolway Farm, Coleford (which has not even been the subject of a planning application during that time), have been subject to repeated planning permissions over a number of years (approximately 30 years in the instance of AP 80 (Former Tinplate Works, Lydbrook)) or actually have expired planning permissions (AP 30 Station Street, Cinderford – in part).

3.25 Further, there are viability matters in relation to a number of the allocations and, whilst some of these may benefit from planning permissions, there are significant question marks in relation to viability (AP 45 Lydney East for example) which results in serious doubt as to whether there is a “realistic prospect” (footnote 11 of the NPPF) of the number of homes identified by the Council coming forward within five years.

3.26 Another example is Site AP 68 (Foley Road, Newent). This site benefits from a planning permission for 120 homes and is currently under construction. The Council has received information from the owner that only 85 homes will be delivered within 5 years. Despite this, the Council has included 120 homes in its five year housing land supply (as evidenced in Table 4.1 in Appendix 4).

3.27 In addition, we have identified potentially significant site constraints in relation to a number of the Council’s other proposed allocations which they consider are capable of delivering homes within the next five years. A few examples of this are set out below:

• AP 16 – Stowfield Lydbrook – This site is a substantial historic former factory site that has been vacant for some time. The site lies on the banks of the River Wye, partly within Flood Zone 3, and wholly within the Area of Outstanding Natural Beauty (AONB) and the Wye Valley Special Area of Conservation (SAC), therefore there is strong possibility of signifcant ecological potential within the site. Whilst the buildings are not listed they have architectural features which may be worth listing • AP 32 – Cinderford Football Club: This site has potentially significant access issues given the narrow width of the proposed access; • AP 34 – Valley Road, Cinderford: The part of the site proposed for development is occupied by vacant buildings but there are operational businesses to the rear (west) of the site (outside the proposed allocation) which would need to be relocated or retain access during construction of the front (east) of the site. Further, the policy requires 2,500 sqm of B1 office floorspace prior to the occupation of any homes;

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• AP 38 – Hill Street, Lydney: The site is currently occupied by an operational builders’ yard which would need to be relocated. The access is narrow with no room for widening given that the steam railway line lies to the east and an operational optician lies to the west; • AP 83 – Mitcheldean former coach depot: The site is accessed via a narrow close and has been vacant for a considerable amount of time, despite lying very close to the centre of Mitcheldean; • AP 95 – Whitecroft Scovill: This is an operational factory occupied by Prim Fashions UK.

3.28 As previously mentioned, the above is a summary of the potential deliverability concerns regarding many of the proposed allocations. There are a significant number of additional proposed allocations where there are similar concerns regarding deliverability (in accordance with footnote 11), and as previously stated, this is addressed in more detail Appendix 4.

3.29 It is therefore considered that a number of the proposed allocations cannot be considered suitable, available or achievable (i.e. deliverable). Consequently, there is not a realistic prospect of many of them delivering the number of homes envisaged by the Council within the next five years.

3.30 A number of the proposed allocations are therefore not effective, in accordance with paragraph 182 of the NPPF. Further, a number of the proposed allocations are not justified as they do not follow the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. The Allocations Plan is therefore unsound on this bases and fails the tests set out in paragraph 182.

Sedbury and Tutshill Proposed Residential Allocations

3.31 As mentioned above, the Allocations Plan identifies two sites in Sedbury and Tutshill for residential development, as ‘alternatives’ to Land at Beachley Road, Sedbury which was previously allocated within the draft Allocations Plan (attached at Appendix 3). These two new ‘alternative’ sites are ‘Land adjoining A48 and Bigstone Meadow, Tutshill’ (ref: AP 89) and ‘The Elms, Sedbury Lane, Sedbury’ (ref: AP 90) and are assessed below.

Site AP 89 – Land adjoining A48 and Bigstone Meadow, Tutshill

3.32 The site is proposed to be allocated for up to 45 homes and extends to 2.6 ha. The Council identifies that 25 homes will be delivered within five years.

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3.33 In consideration of its baseline landscape and visual components and qualities, the site has major drawbacks as a residential development site. Barton Willmore has undertaken a concise Landscape and Visual Appraisal of the site and has summarised the LVA findings as: ‘Key Facts’. This LVA ‘Key Facts’ sheet is contained within Appendix 5.

3.34 Site AP 89 is on high ground, is visually prominent, is poorly related to Tutshill and will require, in the Council’s view, acoustic screening that, in our view, will be difficult to deliver without adversely impacting a large extent of the boundary hedgerow with the A48. This site compares very unfavourably in landscape and visual terms to the advantages of the Land at Beachley Road site.

3.35 This is compounded by the consideration of the site, by Officers, in their responses to the site in the “Allocations DPD Responses to May 2012 Consultation” in 2013, contained below. It must be noted that whilst there are two references, they refer to the same site as the site was subject to two different promotions at different stages of the process:

Council Response ADPD31 - Land at Tutshill, Map Shlaa (2008) 147: “There is an acknowledged requirement for an additional allocation or allocations at Tutshill/Sedbury in order to meet the needs of the district in the manner proposed in the CS. Whilst this site could be evaluated it is considered that the land adjoining Wyedean school is preferable to be developed being better related to the settlement and less prominent in the landscape. No change is therefore proposed.”

Council Response ADPD318 – SHLAA site 147 Junction A48/B4228: “There is an acknowledged requirement for an additional allocation or allocations at Tutshill/Sedbury. This site is one that should be evaluated as a possible option in meeting the requirement. The visual impact of the development of the land concerned is likely to be a major consideration in considering whether it is a site that should be allocated.”

3.36 Further, the Sustainability Appraisal that accompanies the Allocations Plan also addresses this site. Although the information contained within the site specific appraisals is limited, the assessment does identify the site’s landscape impact as red negative, stating that “This site slopes down to the A48 and is very prominent

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location”. Given the paucity of information contained within many of these site appraisals this additional text is telling. The site appraisal is attached at Appendix 6.

Site AP 90 – Land at The Elms, Sedbury Lane, Sedbury

3.37 The site is proposed to be allocated for 50 dwellings and extends to 2.4 ha. The Council considers that 25 homes are deliverable within five years. Sedbury Lane is a single track country lane lined by mature hedges and trees with no pavements or street lighting. It is not suitable for pedestrian/cyclist access. There appears to be insufficient width to accommodate pavements and two way traffic. Irrespective of this, Sedbury Lane is poorly surveilled and isolated.

3.38 Further, and in consideration of its baseline landscape and visual components and qualities, the site has major drawbacks as a residential development site. Barton Willmore has undertaken a concise Landscape and Visual Appraisal of the site and has summarised the LVA findings as: ‘Key Facts’. This LVA ‘Key Facts’ sheet is contained within Appendix 7.

3.39 Site AP 90 declares its problem in its address. Sedbury Lane is tight, narrow, muddy and very rural. Its hedges are gappy. The site sits next to the business area and it will be challenging to make an attractive environment for homes here. The northern boundary is largely open and unbounded for much of its length. Again the relationship with the settlements is divorced and poor. These sites compare very unfavourably in landscape and visual terms to the advantages of the Land at Beachley Road site.

3.40 This is compounded by the consideration of the site, by Officers, in their responses to the site in the “Allocations DPD Responses to May 2012 Consultation” in 2013, contained below.

Council Response ADPD313 – Field west of Sedbury Lane and east of British Legion building: “The site as proposed is considered to be one that could be subject of further investigation regarding its suitability and availability for housing. It and land to the north has been proposed in the SHLAA process and is therefore thought to be potentially available. In the light of the recommendation that land adjoining Wyedean school be proposed it is however not proposed to recommend allocation of this land.”

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3.41 The site appraisal for this site that is contained within the Sustainability Appraisal that accompanies the Allocations Plan is attached at Appendix 8 for completeness, but as mentioned previously the information contained therein is limited.

3.42 Therefore, in light of the above it is considered that proposed allocations AP 89 and AP 90 are not justified as they do not present the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.

3.43 The proposed allocations AP 89 and AP 90 are not effective as there is no robust, up to date evidence that they will be delivered in the Plan period, or indeed whether 25 homes will be delivered on each site within the next five years.

3.44 Given the site known constraints, as well as the potential site constraints, it has not been demonstrated that the either AP 89 or AP 90 are consistent with national policy are unsound.

3.45 Accordingly, the Allocations Plan is unsound as it fails the tests as set out within paragraph 182 of the NPPF in a number of instances.

3.46 Also, and as previously stated, it is considered that the requirement to deliver 6,200 homes in the Core Strategy Plan period from 2006 to 2026 is a constrained figure therefore there is significant doubt as to whether the plan is positive prepared insofar as it does not meet the objectively assessed needs of the district. This introduces an additional question – should the Council be undertaking a complete review to ensure that its development plan is up to date and complies with the full requirements of the NPPF?

3.47 Land at Beachley Road, Sedbury is assessed in detail in Section 4.0.

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4.0 LAND AT BEACHLEY ROAD, SEDBURY

4.1 As set out in Section 3.0 above, it now turns to assess Land at Beachley Road, Sedbury.

4.2 It has already been established in Section 2.0 that Sedbury/Tutshill is a sustainable settlement suitable for residential development, which indeed also benefits proposed sites AP 89 Land adjoining A48 and Bigstone Meadow, Tutshill and AP 90 Land at The Elms, Sedbury Lane, Sedbury to a certain degree therefore it is not necessary to repeat this here.

4.3 However, whilst these three sites are all contained within the same combined settlement, and consequently benefit from Sedbury/Tutshill’s position in the Core Strategy and Settlement Hierarchy, it is still considered pertinent to assess the proximity of the respective sites to local services and facilities on a more micro level.

4.4 Whilst The Elms is closer to a number of the existing facilities on Beachley Road in Sedbury, Land at Beachley Road is still within a comfortable walking distance of those facilities. In addition, as the site is more centrally located within the combined settlement, it is adjacent to and opposite Wyedean Secondary School and Offa’s Mead Academy respectively. It is also closer to Chepstow railway station; Tesco superstore and Chepstow High Street than the two alternative sites.

4.5 The site is therefore well located within the settlement to take maximum advantage of the services and facilities within Sedbury/Tutshill, and indeed Chepstow, with which it is ‘…physically and functionally linked…’ as set out within paragraph 3.28 of the Core Strategy.

4.6 Proposed access is via a 5th arm off the Wyebank Road/Beachley Road roundabout and footway improvements (as set out within the outline planning application) can comfortably be achieved.

4.7 No technical objections were raised during the course of the planning application that were not comfortably resolved, subject to conditions and planning obligations. Whilst Members resolved to refuse the outline planning application, against Officer advice, in May 2014, it is not considered that the development of the site will lead to a “significant visual intrusion as set out within the refusal reason. Landscape matters are dealt with in detail below but it has therefore been demonstrated that there are no technical reasons as to why the site could not come forward for residential development.

17109/A5/CP Page 17 September 2014 Land at Beachley Road, Sedbury

4.8 The shape of the site with its strong hedges boundaries actually limits the open nature of the eastern side. The site also enjoys considerable physical and visual containment around its boundaries and edges; it is a very well contained settlement-edge site.

4.9 Land at Beachley Road sits comparatively low in the landscape. It is not a prominent site sitting on high ground as stated in the reasons for refusal of planning permission. Tutshill to the north is a village on a hill. The high point of the hill at 67m AOD is 25m higher than the site at its high point of 42mAOD. There are other high points around the site a little south of Sedbury, at Sedbury Park and further east at Bakers Wood (57m AOD).

4.10 The visual characteristic is one of containment. Only its eastern boundary is relatively open and even then the views and the scale of the landscape is partitioned in the fore and middle ground by hedges and by lanes and roads. The site sits next to the settlement and its character is influenced by both rural and urban character drivers. Even at the eastern and most open edge of the appeal site it possesses a degree of intimacy and a relatively small scale range of views. The view into the eastern area of the appeal site from the PROW at Sedbury Lane shows this enclosed and visually discrete quality. The enclosing nature of the high hedges restricts views out of the appeal site.

4.11 Apart from the numerous trees so common to the appeal site’s boundaries, there is only one tree on site. All the areas of trees that have particular significance in the setting such as the woods at Tutshill and Sedbury Park, the plantation like large copse at the eastern end of Wyedean School playing fields and Park Grove. The site is not reliant on the trees but the existence of so many trees accentuates the containment of the appeal site within its setting. The characterisation of this containing quality is the sum of the parts or components of the landscape that create the containment - landform, proximity of the settlement edge, road and railway corridors, field shape, hedgerow prominence and tree cover in the setting.

4.12 In terms of landscape character, at the national level, the development of the appeal site will not cause harm to the National Character Area (NCA) 106 “Severn and Avon Vales” within which it sits. The important components within the Council’s Landscape Character Type (LCT) ‘6. Unwooded Vale (the “deeply rural landscapes of the Unwooded Vale landscape type”) are not manifest on the site; it is too close to the settlements for this description to fit. The proximity of Chepstow, Sedbury and Tutshill is such that there is an urbanising presence that is palpable on the appeal site. The school, the roads, the railway and the concentration of population are all present as

17109/A5/CP Page 18 September 2014 Land at Beachley Road, Sedbury

components in this edge of settlement, rural urban fringe landscape. It is not a deeply rural landscape. It is adjacent to the urban edge and to numerous roads, all of which generate noise. It is not deep into the Forest, or the Wye Valley AONB. There are numerous walkers on the Public Right of Way across the appeal site. It sits next to a secondary school, and Sedbury Lane, now severed by the A48, has a dead end that is littered with the detritus associated with near settlement lay-bys.

4.13 It exhibits some of the landform and intimacy of the LCT but its particular location at the settlement edge stops it from possessing the substantive characteristics that the FODDC study uses to make the definition.

4.14 Both the shape and scale of the local landform contribute to the physical containment of the site. The extensive, substantial well defined hedgerow boundaries further reinforce the discrete nature of the site and set it apart from the wider countryside north of Sedbury Lane to a strong degree. The least contained boundary is with Sedbury Lane and yet from viewpoints at gateways along the lane the site is seen against a backdrop of the settlement. The site is clearly influenced by urban activities from its settlement fringe location.

4.15 As set out in the previous section in relation to the two ‘alternative’ sites proposed within Sedbury/Tutshill, the Council responses in relation to Land at Beachley Road in the “Allocations DPD Responses to May 2012 Consultation” in 2013 are below. Again, as the site was subject to a number of promotions there are a number of appraisals of the site:

Council Response ADPD218 – Land adjoining Wyedean School, Beachley Road, Sedbury: “This site is considered to be one that should be considered for development at Tutshill/Sedbury. It is generally well located and its potential as a housing allocation should be examined further. The CS requires the allocation of additional land at Tutshill Sedbury for housing.”

Council Response ADPD222 – Land at Beachley Hill, Beachley Road, Sedbury: “There is a need to allocate land at Tutshill/ Sedbury as defined in the CS. This site is considered one that should be evaluated as a possible allocation for housing. It is considered that the evaluation should be on the basis of the submitted indicative plan which shows the western part of the land being developed and the eastern section being used as open space.”

17109/A5/CP Page 19 September 2014 Land at Beachley Road, Sedbury

Council Response ADPD289 – Fields to rear of Wyedean School, Sedbury, between A48 and the link road: “This site is one that is recommended as a potential site for additional housing. It is well related to the existing settlement and the services it offers. The site is in a location where landscaping and design will be important and the ultimate development if it is allocated should include functional open space. Whilst the examination of whether the site should be allocated will consider the entire area identified by the Parish Council, the potential for identification of only part of the site will also be examined.”

Council Response ADPD328 – Site 213 Wyedean School: “It is recommended that this site be recommended as a possible allocation for housing in Tutshill/ Sedbury. It is well related to the existing settlement and may have potential for meeting the CS requirement or part of it. The whole area identified by the Parish Council may not be suitable but this will be investigated as part of the evaluation. The figure of 222 dwellings referred to in the representation is well in excess of the CS requirement for dwellings in Tutshill/Sedbury.”

4.16 Further, the Sustainability Appraisal that accompanies the Allocations Plan also addresses this site. Although the information contained within the site specific appraisals is limited, the assessment identifies “few constraints”. Landscape impact is identified as a potential constraint, but the score that is achieved on this matter is amber zero with no additional commentary on this subject. Groundwater drinking water is identified as a potential constraint but there were no objections from the Environment Agency or the Council in this regard during the determination of the planning application. The proximity to the settlement boundary attracts a red negative score, which is difficult to understand given the lack of additional commentary in the appraisal, the fact that the site lies adjacent to the settlement boundary, is located centrally within the combined settlement, the conclusions on landscape matters and the fact that the does not extend as far east as the two alternative sites. The site appraisal is attached at Appendix 9.

4.17 It is therefore clear that the Council’s evidence base confirms that Officers considered that the appeal site was more appropriate for a residential allocation than the two new proposed allocations.

17109/A5/CP Page 20 September 2014 Land at Beachley Road, Sedbury

4.18 It is therefore not considered that the development of the site would be detrimental to the immediate countryside at the settlement edge nor would it compromise the distinction between Tutshill and Sedbury as it is so well defined, bounded and contained by landform, hedgerow pattern and the settlements.

4.19 It is therefore considered appropriate to allocate the site for residential development on visual and landscape grounds.

4.20 Finally in this regard, the site needs to be assessed against footnote 11 of the NPPF. The site is available now, evidenced by the fact that the landowners have supported the submission of the outline planning application and have signed the two Section 106 Agreements with Forest of Dean District Council (securing affordable housing and the provision, laying out and maintenance of public open spaces) and Gloucestershire Council (securing a Travel Plan) that have been completed in relation to the Section 78 appeal that is currently ongoing.

4.21 Further, Barratt Homes is willing to accept a reduced time period for the submission of reserved matters within the relevant condition to ensure quicker delivery of homes on site, as requested by the Council during discussions on the Statement of Common Ground for the appeal.

4.22 It has been demonstrated above that the site offers a suitable location for development, evidenced by the fact that Sedbury/Tutshill is considered to be a sustainable location for residential development and the lack of technical objections that were raised during the planning application process.

4.23 The site is also achievable and has a realistic prospect of delivering homes (both market and affordable housing) within the next five years, again evidenced by the landowners’ and appellant’s intentions and the willingness to accept a reduced time period within to submit reserved matters.

4.24 The site is therefore deliverable in accordance with footnote 11 and should be allocated for residential development.

4.25 It has been demonstrated that the allocation of the site is the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. The proposed allocation site is therefore justified.

4.26 It has been demonstrated that the site can deliver 110 homes in the next five years, by virtue of the outline planning application that has been submitted, the subsequent Section 78 appeal and the signed Section 106 Agreements contained within that

17109/A5/CP Page 21 September 2014 Land at Beachley Road, Sedbury

appeal. Further, the appellant is willing to accept a shorter time period to submit reserved matters. The proposed allocation is therefore effective.

4.27 It has been demonstrated that the proposed allocation is consistent with national policy, as evidenced by the initial allocation of the site by Members and Officers and the Officer recommendation for approval of the planning application.

4.28 The proposed allocation of Land at Beachley Road therefore complies with paragraph 182 of the NPPF and is a sound allocation.

4.29 Finally, the site should be allocated for residential development in order to make the Allocations Plan sound given the requirement for the Council to deliver homes in the Plan period 2006 to 2026, the fact that the Council is failing to deliver those homes at present, the significant constraints identified above in relation to a number of the proposed allocations within the Allocations Plan (not least the two ‘alternative’ sites that have been proposed in Sedbury/Tutshill and the need to ensure that homes are delivered in accordance with the spatial strategy set out in the Core Strategy. This is also against the backdrop that the requirement to deliver 6,200 homes in the Core Strategy over the Plan period is a constrained figure.

17109/A5/CP Page 22 September 2014 Conclusions

5.0 CONCLUSIONS

5.1 It has been demonstrated above that Sedbury/Tutshill is a sustainable location for residential development, evidenced by the Core Strategy and Settlement Hierarchy which designates the site as a Major Village (which is the second tier in the settlement hierarchy) and identifies the settlement as being at the top of the second tier as it is the ‘fifth’ settlement within the district.

5.2 Further, the Core Strategy requires the delivery of a number of homes within the combined settlement of Sedbury/Tutshill over the Plan period 2006 to 2026, which will make an important contribution to the Council’s requirement to deliver 6,200 homes over the Plan period; it has also been established that these figures are not to be viewed as “ceilings”.

5.3 It has been demonstrated that the requirement to deliver 6,200 homes over the Plan period 2006 to 2026 is a constrained figure given that the evidence within the Draft RSS for the South West identified a need for 8,272 homes over the same period.

5.4 It has been confirmed that the Allocations Plan does not contain a housing trajectory. There is therefore no robust, up to date evidence to demonstrate that the number of homes proposed can be delivered over the different time periods of the Plan, and in particularly over the next five years.

5.5 It has also been demonstrated that the Council is failing to deliver sufficient homes against its Core Strategy requirement, and indeed has persistently failed to deliver its requirement. This is evidenced by the fact that the Council has met its basic housing requirement only 4 times in 23 years (over two development plan periods – the Structure Plan and the Core Strategy) and has indeed resulted in the Council accepting that it should be considered a “20%” authority in accordance with paragraph 47 of the NPPF.

5.6 In addition, it has been confirmed that paragraph 47 of the NPPF, which sets out the requirement “To boost significantly the supply of housing”, is a primary consideration. It must be noted that this requirement applies to both market and affordable housing.

5.7 This “scene setting” therefore provides an important context within which the Allocations Plan needs to be considered.

17109/A5/CP Page 23 September 2014 Conclusions

5.8 In terms of the procedural requirements set out within paragraph 182 of the NPPF and Section 110 of The Localism Act 2011, there is no clear evidence that the Council has undertaken its duty to cooperate.

5.9 Barratt Homes supports the first sentence of Allocations Plan Policy AP 1 insofar as it sets out that the economic, social and environmental role of the planning system (paragraph 7 of the NPPF) and that these requirements are separated from the following sentence which refers to specific allocations. i.e. a proposed development does not need to be subject to an allocation within a Local Plan.

5.10 It has been demonstrated that a number of the proposed housing allocations are not effective, not justified and not consistent with national policy, as required by paragraph 182 of the NPPF. It therefore follows that they are unsound for a number of reasons (particularly in relation to delivering homes within the next five years as the need for housing is now).

5.11 Further, it has been demonstrated that the two new proposed ‘alternative’ sites within Sedbury/Tutshill are not effective, justified or consistent with national policy as required by paragraph 182. They are therefore unsound. Indeed, it is evident that Officers considered Land at Beachley Road, Sedbury as a more appropriate site to be allocated for residential development in its own evidence base.

5.12 In addition, it has been confirmed that Land at Beachley Road, Sedbury is justified, effective and consistent with national policy and as such is a sound allocation. It is required to be allocated for residential development to make the Allocations Plan sound given the shortcomings within the plan as identified above.

5.13 Finally, given the above, it is evident that modifications are required to be made to the Allocations Plan which will require additional work by the Council and possibly the need for further public consultation. This will inevitably lead to more delays in the adoption process, which has already been subject to significant delays.

5.14 The Inspector is therefore respectfully requested to allocate Land at Beachley Road, Sedbury for residential development within the Allocations Plan.

17109/A5/CP Page 24 September 2014 APPENDIX 1

Site Location Plan The scaling of this drawing cannot be assured Revision Date Initial

Site Application Boundary

Land within the control of the

THE MYRTLES applicant CHASE SEDBURY

SEDBURY LANE SP

SP

Wye Valley Junction

CASTLE VIEW

SEVERN AVENUE

Tunnel SEDBURY LANE

THE MARTINS

Project Sedbury Tutshill Chepstow Drawing Title Site Location Boundary

Date Scale Drawn by 28.10.13 1:2500@A3 MV

Project No Drawing No Revision 17109

EDMOND ROAD

GRAHAMSTOWN GROVE 3ODQQLQJł0DVWHU3ODQQLQJ 8UEDQ'HVLJQ $UFKLWHFWXUHł/DQGVFDSH3ODQQLQJ 'HVLJQł3URMHFW6HUYLFHV (QYLURQPHQWDO 6XVWDLQDELOLW\$VVHVVPHQWł*UDSKLF'HVLJQ

HENDRICK DRIVE bartonwillmore.co.uk

003 WYEBANK CRESCENT Certificate FS 29637 Offices at Reading Bristol Cambridge Edinburgh Leeds Solihull West Malling (Kent) Reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No 100019279. J:\17000 - 17999\17100 - 17199\17109 - Sedbury Tutshill\A4 - Dwgs & Registers\CAD\CAD\17109_Boundaries.dwg - A3 APPENDIX 2

Illustrative Masterplan Wye Valley Junction

SEVERN AVENUE Tunnel

THE MARTINS

EDMOND ROAD

Project Site Boundary Proposed Tree/Hedgerow Sedbury Tutshill Planting Chepstow Drawing Title Vehicular Access Point PRoW Illustrative Masterplan

Date Scale Drawn by Pedestrian/Cycle Access Point LEAP (Local Equipped Area of 22.10.13 1:1000 MV Play) Project No Drawing No Revision 17109 9700 G Residential LAP (Local Area of Play)

Green Open Space Proposed Pitch

3ODQQLQJł0DVWHU3ODQQLQJ 8UEDQ'HVLJQ $UFKLWHFWXUHł/DQGVFDSH3ODQQLQJ 'HVLJQł3URMHFW6HUYLFHV Retained Trees/Hedgerows (QYLURQPHQWDO 6XVWDLQDELOLW\$VVHVVPHQWł*UDSKLF'HVLJQ bartonwillmore.co.uk

003

Certificate FS 29637 Offices at Reading London Bristol Cambridge Edinburgh Leeds Solihull West Malling (Kent) J:\17000 - 17999\17100 - 17199\17109 - Sedbury Tutshill\A4 - Dwgs & Registers\CAD\CAD\17109_9700_Illustrative Masterplan_Rev F_MV.dwg - Layout3-A2

Reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No. 100019279. APPENDIX 3

Draft Allocations Plan Extract (pre Pre-Publication Draft)

APPENDIX 4

Site Assessments APPENDIX 4: ASSESSMENT OF DRAFT PROPOSED ALLOCATIONS

1.1 The below paragraphs contain Barratt Homes’ summary of the proposed residential allocations contained within the draft Allocations Plan. Site ID References are as per the draft Allocations Plan.

1.2 A secondary Site ID Reference is also included and this corresponds to Table 4.1 at the end of this Appendix. Table 4.1 is a tabulated assessment of all the sites contained within the Council’s land supply schedule. This table contains 85 sites and the sites are therefore numbered 1-85. This table has been included within the Proof of Evidence submitted for the Section 78 appeal on Land at Beachley Road, Sedbury; the inquiry is due to commence on 30th September.

1.3 The green sites within the table are not disputed with the Council and are therefore not assessed below. The pink sites in the table are disputed and are therefore assessed below. Consequently, not all 85 sites are assessed below, and it therefore follows that not all of the references 1-85 are contained below.

1.4 Not all of the pink sites are proposed allocations within the Allocations Plan but they are all addressed below for completeness. Further, the site names sometimes differ between the Council’s schedule and the draft Allocations Plan. This document uses the names used within the draft Allocations Plan.

1.5 Finally, some residential development is proposed to be focussed to the town centres, but as the numbers proposed within those comprehensive schemes have not been identified, nor does the Council consider that these sites will deliver homes within the next five years, they are not assessed below.

1.6 In summary, given the lack of clear, transparent, robust or up to date evidence, there are significant question marks regarding many of the proposed allocations at this stage, and whether they can deliver the number of homes identified by the Council within the Plan period to 2026 (let alone within five years as the Council has assumed on a number of occasions).

1.7 Therefore, many of the proposed allocations do not currently comply with paragraph 182 of the NPPF in that they are not justified, effective and/or consistent with national policy.

Proposed Allocations in Draft Allocations Plan

AP 16 Stowfield Lydbrook (Site ID No 63)

1.8 A site of 9ha is proposed to be allocated for about 45 homes in the Draft Allocations Plan, including at least 4ha of employment (B1, B2 and B8) a hotel and pub, recreation facilities and a care home. The Council identifies the delivery of 25 homes within the 5 year period.

1.9 The site is a large former factory on the banks of the River Wye, within the Area of Outstanding Natural Beauty (AONB), and within the Wye Valley Special Area of Conservation (SAC). The site is therefore in a very sensitive location, is isolated and freestanding from a sustainable village or settlement. A significant element of the site lies within Flood Zone 3, affecting the frontage of the site and its potential sole access and egress location. The site was originally erected in 1916 and benefits from a number of architectural and historic features therefore there could be potential for the buildings to be listed. The site does not have planning permission.

1.10 Given the above significant issues associated with the development of the site there is no robust, up to date evidence that this site can achieve planning permission and deliver 25 homes within the 5 year period, or indeed the Plan period to 2026. The proposed allocation therefore does not comply with paragraph 182 of the NPPF.

AP 30 Station Street, Cinderford (Railway Tavern element of AP 30) (Site ID No 5)

1.11 The site has an extensive history for conversion to residential uses. P0256/12/COU was an application to extend the time limit to planning permission P0604/08/COU – conversion of former public house to create 10 apartments and associated works. The decision was granted on 16th August 2012, subject to a 3 year condition requiring commencement of works on site within this period. The site forms part of a wider allocation for 150 homes within the draft Allocations Plan (alongside Site ID Nos. 7, 8 and 9).

1.12 The parent permission was PINS Ref APP/P1615/A/08/2087593 - Conversion of former public house to create ten apartments and associated works. This was allowed on 2nd April 2009. The appealed application was the above referenced P0604/08/COU for the conversion and extension to former public house to create 10 apartments and associated works, which was refused in August 2008. Prior to which there were two additional applications: DF7267/A, an outline application for residential development – withdrawn in 2007 and DF7267/B for the Conversion of pub to 11 apartments, which was refused in 2007.

1.13 In addition, the site is surrounded on three sides by the operational Rothdean manufacturing site, which produces Heavy Goods Vehicle Trailers. Whilst potentially separately implementable, due to the surrounding existing heavy industrial use it is clear that this has stymied the conversion of the building to apartments. This is because the surrounding Rothdean factory does not present a suitable environment and will severely curtail the potential market for purchasers of the proposed apartments. There is therefore no robust, up to date evidence that there is a realistic prospect that homes will be deliver don site within the nexy five years, or indeed the remainder of the Plan period, particularly whilst Rothdean is operational, as evidenced by its extensive planning history. The site is therefore not available.

AP 30 Station Street, Cinderford (Rothdean factory element) (Site ID No 7)

1.14 This is the existing Rothdean factory site and forms part of the overall Cinderford Station Street allocation within the draft Allocations Plan which extends to 4.5 hectares, and is proposed to be allocated for 150 homes (alongside Site ID Nos. 5, 8 and 9). The site was also allocated within the 2005 Local Plan as part of a wider allocation. The draft Allocations Plan states (para 5.15) that the site benefits from four separately implementable planning permissions. The individual sites however have extensive planning histories for redevelopment to housing. The site comprises the St Cannop Foundry, the Wilce Land, the Former Lister Works and the Railway Station Tavern. However the planning permissions for all, apart from the Railway Station Tavern (see above), have expired.

1.15 The Former Lister Works (Rothdean part of the site) has repeated permissions for residential development dating back to 2004, via application ref: DF336/V and P1590/04/OUT which was as a renewal of consent for residential development (granted 18 November 2004). Subsequently, reserved matters for: Residential development of 100 dwellings and ancillary works (ref: P1578/07/APP DF336/V/AP), was granted 12 March 2008 and prestart conditions have been approved P0016/10/DISCON & Discharge Conditions 6, 11, 12, 2 & 3 P0183/09/DISCON on 11th March 2010.

1.16 The LPA identifies that the planning permission has been implemented. However there does not appear to be any evidence of this on the ground nor has it resulted in any significant works on the site, given the continued operational nature of the site by Rothdean. The Rothdean site is therefore not available now for residential development.

1.17 Furthermore, given the history of separate applications there clearly are landownership/assembly issues that have stymied delivery of any homes on the site for over 10 years. This is also referenced in the Committee Report for the Wilce Land (Site ID No 9 below).

1.18 On the above basis it is considered that the Former Lister Works (existing Rothdean Site) is not available now and there is no robust, up to date evidence that there is a realistic prospect of delivering housing on the site in the 5 year period. Accordingly the site should be discounted from the 5 year land supply as the proposed allocation does not comply with paragraph 182 of the NPPF.

AP 30 Station Street, Cinderford (Cannop Foundry element) (Site ID No: 8)

1.19 The site is a former foundry site. The site forms part of a wider allocation for 150 homes within the draft Allocations Plan (alongside Site ID Nos. 5, 7 and 9). The site was also allocated within the 2005 Local Plan as part of a wider allocation. The site has an extensive planning history for its redevelopment to housing, dating to back 1990. The LPA reference in the schedule is permission P0539/08, which is an application for reserved matters approval for 30 dwellings which was refused by the Council (dated 17th October 2008) and allowed on appeal on 7th July 2009 (APP/P1615/A/09/2100797). No subsequent application for discharge of pre-start conditions have been made or S73 applications to renew the planning permission. The outline permission was granted in October 2005 therefore this permission has now expired. The outline planning permission for the Reserved Matters is LPA Ref P8869/03 which, according to the Council’s database, expired on 12th October 2008.

1.20 Therefore there is robust, up to date evidence that there is a realistic prospect that the site will deliver homes within the next five years, or indeed the remainder of the Plan period, and it should therefore be discounted from the 5 year supply as the proposed allocation does not comply with paragraph 182 of the NPPF.

AP 30 Station Street, Cinderford (Wilce Land element) (Site ID No 9)

1.21 This site is also part of the Cinderford Station Street Allocation in the draft Allocations Plan (alongside Site ID Nos. 5, 7 and 8). The site was also allocated within the 2005 Local Plan as part of a wider allocation. The site also benefited from full planning permission (LPA Ref P0885/10) for the development of 22 homes and associated works granted on 10th November 2010. Condition 1 requires the commencement of development within 3 years of the date of permission. There are several pre-start conditions. There is no record of these being discharged or of new planning applications/renewals. The Officer Report identifies that there are significant contamination issues associated with the site and that there is a 50% overage clause on the potential redevelopment of the site; the applicant identifies that this renders the site unviable.

1.22 The planning permission has therefore expired and it is evident that there are significant contamination and viability issues associated with the site which have ensured that it has not been developed to date. On this basis there is no robust, up to date evidence that the site will deliver homes within five years, or indeed the remainder of the Plan period to 2026 and therefore the proposed allocation does not comply with paragraph 182 of the NPPF.

AP 32 Cinderford Football Club (Site ID No 61)

1.23 The site of 6.6 ha is proposed to be allocated for the development of about 90 homes on 2.4 hectares including the entire land occupied by the present football club, 4.2 ha of land to provide a relocated football club, and 0.9ha of land for public open space. The Council considers that 50 homes can be developed within five years. The football club has to be relocated and the open space replaced before the commencement of development of the proposed homes. The housing trajectory of November 2013 identifies the delivery of 40 homes within the 5 year period. However the Council has increased this to 50 in the present schedule.

1.24 However, the site does not benefit from planning permission. Further, in deliverability terms, it is necessary to provide for the relocation of Cinderford Football Club in advance of the completion of any homes. This will require agreement of the Football Club and its league. Additionally, the necessary infrastructure (such as a new club house, changing room, football pitch and associated works) will be a very costly element, in addition to Section 106 obligations and the need for 40% affordable housing. The access to the site from Edge Hills Road is narrow and appears to be insufficient to safely accommodate a two way carriageway and footpaths without the potential for conflict of movements between vehicles and pedestrians.

1.25 For the above reasons it is not considered that the proposed allocation is in accord with paragraph 182 of the NPPF.

AP 34 Valley Road, Cinderford (Site ID No 72)

1.26 The site of 2.6 ha is proposed for mixed employment (1.2ha) and 45 homes on 1.4 ha. The Council identifies the delivery of 30 homes within the 5 year period. The site comprises an area of existing vacant buildings at the eastern end of the site, although there are buildings in occupation towards the western end. The site does not benefit from planning permission. Additionally, there is a requirement to deliver 2,500 sqm of B1 employment floorspace prior to the occupation of any homes, which alongside the requirement for 40% affordable homes and other S106 contributions would likely render such a development unviable.

1.27 For the above reasons the site is not available now and not genuinely deliverable with a realistic prospect of delivering 30 homes within the 5 year period, or indeed over the remainder of the Plan period to 2026. The proposed allocation therefore does not comply with paragraph 182 of the NPPF.

AP 38 Hill Street, Lydney (Site ID No 76)

1.28 The site is allocated for mixed residential development for up to 25 homes, as apartments over retail/commercial uses. The Council considers that 10 homes will be delivered within five years. The site is occupied by three separate small retail premises on Hill Street and a Travis Perkins builders’ yard to the rear. The builders’ yard is accessed via a narrow lane adjoining the and level crossing to the west and David Kear Opticians to the east.

1.29 It does not appear that the access is of sufficient width to be able to safely accommodate a two way carriageway and footpaths without the potential for conflict of movements between vehicles and pedestrians. To achieve an access may therefore require the demolition of one or more of the existing retail units on the street frontage.

1.30 Given the absence of planning permission, and the likely need for site assembly, particularly to provide a suitable access for the rear area of the site, it is considered that the site is not available now and that there is no robust, up to date evidence that the above constraints can be overcome. The proposed allocation therefore does not comply with paragraph 182 of the NPPF.

AP 45 East of Lydney (part) (Site ID Nos 16 and 17)

1.31 These sites are effectively two phases of the same site given the common infrastructure requirements needed to serve both developments therefore they are addressed together. The 192 homes referred to above are contained within Phase B (Site ID No 17). The Council doesn’t consider that any homes will be delivered in Phase A (Site ID No 16) within five years.

1.32 AP 45 is proposed to be allocated in the draft Allocations Plan for approximately 1,553 homes, 25.8 ha of employment uses, a neighbourhood centre, a park, open space and a primary school (AP45).

1.33 Lydney A benefits from Outline planning permission (Ref P0412/13/OUT) for the development of up to 300 dwellings and subject to a Unilateral Undertaking of 10th June 2010 which requires 20% of the homes to be affordable, with 50% social rent and 50% shared ownership. This was allowed at appeal on 1st July 2008 (recovered by the Secretary of State – Ref APP/P1615/A/07/2042254).

1.34 Lydney B benefits from outline planning permission (Ref P1097/08/OUT), which was allowed at appeal (PINS Ref APP/P/1615/A/09/2108057) for the development of up to 750 dwellings and subject to a Unilateral Undertaking (dated 11th May 2010) which requires the delivery of 30% affordable housing - with 65% for social rent and 35% as intermediate housing.

1.35 Robert Hitchins applied to vary the S106 Agreement to remove the need to provide any affordable housing on the site, Ref: P1809/13/PLANOB. That application was refused by the Council and considered at a recent Inquiry. The appeal (PINS Ref APP/P1615/Q/14/2215840) was allowed on the 3rd September 2014, reducing the level of affordable housing contributions on the site from 20% (on Lydney A) and 30% (on Lydney B) to 14.1% overall across both sites for a period of 3 years from 3rd September 2014. The Council identifies that 192 homes would be provided on the site within a 5 year period.

1.36 However this appears optimistic. Robert Hitchins is not a housing developer. Accordingly, marketing will be required to obtain a developer for the site, or part of the site. This will be contingent upon an acceptable offer being made for the site (or part of the site) from a developer and following necessary due diligence (i.e. planning, technical and legal checks including requirement for Board approval from the developer). Following which the developer would need to prepare, submit and obtain approval of reserved matters from the Council and discharge any necessary pre-start conditions. It would then be necessary to deliver significant common infrastructure i.e. roads, drainage and other works in order to make a start on site, as identified in the recent appeal. It is also clear that design issues need to be resolved, particularly in relation to density and, subsequently, total housing numbers. This will also have an impact on viability and could comfortably take up to 2.5 years to complete.

1.37 The Inspector’s decision identifies an assumed sales rate of 4.7 homes per month, or 56 homes per year. Allowing for 2.5 years, this would leave only 6 months remaining (given that the reduced level of affordable housing only remains in force for three years) which, on the above rates, could deliver 28 homes. However the Appellant in this appeal identified a sales rate of between 2 and 4 homes per month i.e. 24 to 48 homes per year, which could therefore deliver 12 to 24 homes within the 6 month period.

1.38 At the end of the three year period, the reduction in affordable housing provision ceases and therefore it cannot be assumed that development would continue for the remainder of the 5 year period, given that the appeal was lodged by the appellant as the original level of affordable housing was not viable – indeed, the Committee Report for the application states that Roberts Hitchins considers the site unviable with 0% affordable housing.

1.39 This is a complex and difficult site, evident from its previous planning history and identified viability issues. It is considered that there is a potential, but no robust, up to evidence that there is a strong and realistic prospect (as per Footnote 11 of the NPPF), that between 12 and 28 homes could be delivered on the site in the 5 year period.

AP 50 Holms Farm – Housing Site (Site ID No 18)

1.40 The site of 1.8 ha is proposed to be allocated for 27 homes. It has been allocated since 2005 within the Local Plan. The site benefited from outline planning permission for residential development (LPA RE P1325/06/OUT) granted on 3rd January 2008. Condition 1 requires the submission of reserved matters within 3 years and condition 2 requires the commencement of development within 2 years of submission of the last of the reserved matters. There is no evidence of Reserved Matters or renewals of outline permission or subsequent applications. The Outline Planning Permission has therefore expired.

1.41 The allocation site itself is heavily overgrown along with existing barns and farm buildings. There is potential for significant ecology issues including bats (relating to Lesser Horseshoe Bats).

1.42 Given the above, and the fact that there is no robust, up to date evidence demonstrating the site’s deliverability within the next five years, or indeed the whole Plan period to 2026, it is not considered that this site complies with paragraph 182 of the NPPF.

AP 51 Augustus Way, Lydney (Site ID No 64)

1.43 The site of 0.85 ha is identified for development in the Draft Allocations Plan for about 25 dwellings. An application was recently refused for the development of the site by the Council on landscape grounds and this is now subject of an appeal.

1.44 At present therefore there is no robust, up to date evidence that the site can deliver homes within the next five years, or indeed the Plan period to 2026, although the outcome of the appeal may change this, particularly if the appeal is allowed.

AP 54 Lawnstone House, Coleford (Site ID No 74)

1.45 The site of 0.17 hectares is proposed to be allocated in the draft Allocations Plan via Policy AP54. The site is provisionally allocated for retail, business and or community use and for residential development (up to about 8 flats). The site consists of vacant former Council office buildings. The site has not been formerly marketed and is not available for development.

1.46 For the above reasons there is no robust, up to date evidence that the entire allocation can be delivered within the Plan period. The proposed allocation therefore does not comply with paragraph 182 of the NPPF.

AP 56 Kings Head Public House, Coleford (Site ID No 73)

1.47 The site is the existing Kings Head Public House, which became vacant in 2014. It is proposed for conversion to 12no 1 and 2 bed apartments. The site does not benefit from planning permission. The building is historic, and is likely to contain compromised floor to ceiling heights, likely unsuitable access arrangements (Part M for disabled access and fire regulations) and would potentially not yield suitable living accommodation space throughout the property. These are issues that would need to be addressed in the conversion of the building to apartments, alongside issues of the market demand and viability of such a scheme.

AP 61 Land at Poolway Farm, Coleford (Site ID No 12)

1.48 The site of 2.6 ha is proposed to be allocated for 80 homes in the Draft Allocations Plan. The supporting text identifies that the site was previously allocated in the former 2005 Local Plan and that no planning applications have been made on the site. Even though the site has been allocated in the Local Plan since 2005 it has not been subject of an application for housing development. Whilst the Council identifies that it has been subject to pre-application discussions, this does not in itself identify that planning permission and development will be forthcoming on the site, particularly given that the site has been allocated for 9 years. Accordingly, given the history of the site to date, i.e. the site has benefited from a Local Plan allocation for housing development but has not been subject to a planning application for housing, there is no robust, up to date evidence that there is a realistic prospect of homes being delivered on the site within the next five years, or indeed the remainder of the Plan period to 2026 and therefore does not accord with paragraph 182 of the NPPF.

AP 68 Foley Road, Newent (Site ID No 54)

1.49 The site of 4.6 ha benefits from outline planning permission for 120 homes which was allowed at appeal (PINS Ref APP/P1615/A/12/2177029) on the 31st December 2012. The appellant was the Gloucester Land Company Limited. Condition 2 requires the submission of Reserved Matters within 3 years of date of the permission. The site is proposed to be allocated within the draft Allocations Plan (Draft Allocations Plan Ref: AP68).

1.50 The adjoining land to the north west is a Linden Homes development site which is under construction as “Meadow Grove”. The Meadow Grove site for Linden Homes is a scheme of 106 homes, of which 85% are reportedly sold.

1.51 The landowner has however identified to the Council that the Foley Road site for 120 homes is likely to only accommodate 85 homes (as confirmed within the Housing Land Supply Statement of Common Ground Addendum that has been submitted with the Section 78 appeal for Land at Beachley Road, Sedbury). This has been reflected in the Council’s comments in the schedule but the Council still considers that 120 homes are deliverable within five years.

AP 73 New Road and High Street, Bream (Site ID No 71)

1.52 The site of 1.6 ha is proposed to provide 30 homes, a new club house, parking for the rugby club and retailing. The site consists of the rugby club building and its associated car park, as well as a funeral director, hair dressers and a builder’s yard. The Council considers that 15 homes will be delivered in the first five years.

1.53 The site is therefore in multiple existing uses and occupied by existing businesses. It will be necessary to undertake land assembly, develop a new rugby club on the site and then demolish the old rugby club before constructing the proposed 30 homes.

1.54 A recent outline application LPA ref P0872/13/OUT, for demolition of the existing clubhouse, associated changing rooms and outbuilding and redevelopment of the site to provide residential dwellings (14no) and new clubhouse and associated parking facilities was withdrawn. A revised application for 14 homes was considered at Committee in September 2014 and was resolved to be approved subject to the completion of a Section 106 Agreement.

1.55 Given that no planning permission exists, the exiting uses on site and the significant works required prior to development commencing, site is not genuinely available now. Accordingly there is not a realistic prospect of the site being developed for 15 homes within the next 5 years. Further, the outline applications above sought the delivery of only 14 homes. The proposed allocation therefore cannot, at present, comply with paragraph 182 of the NPPF.

1.56 Whilst proposed to be allocated for development to housing, the site is not presently on the market publicly and therefore is not genuinely available now. Additionally, as a previous public house which has only recently become vacant, there is potential that a new tenant or purchaser could run the public house on a successful basis and not wish to convert the building to apartments.

1.57 For the above reasons there is no robust, up to date evidence that the entire allocation can be delivered within the Plan period. The proposed allocation therefore does not comply with paragraph 182 of the NPPF.

AP 80 Former Tinplate Works, Lydbrook (Site ID No 44)

1.58 The site has been subject to applications for residential development for housing since 1985. Planning permissions for housing have either lapsed or been renewed on a continual basis since that time. The latest outline planning permission P1303/13 provides for the development of 26 homes with ancillary works and was granted on 17th July 2014.

1.59 The Environment Agency raised issues in relation to the proposed approval of the application in its letter of 9th July 2014. The letter identifies that the submitted Flood Risk Assessment left significant unresolved matters which needed to be addressed prior to the grant of planning permission. However, due to the Council’s position identifying its desire to approve the application, the EA identifies that two conditions are required to be complied with prior to the commencement of development. Condition 20 requires the design of a suitable open drainage channel which is capable of accommodating the 1:100 plus climate change flood event. The EA also identifies that due to the design requirements for this drainage channel, including its physical dimensions and requirements for maintenance access, that this may well reduce the number of homes able to be delivered on the site. In addition, Condition 21 requires the applicant to demonstrate that suitable means of emergency access can be achieved from the site in times of flood within a 1:100 year event plus an allowance for climate change.

1.60 These are significant issues which are normally resolved at the outline stage given that they fundamentally affect the deliverability and suitability of a site for residential development.

1.61 The deliverability of the site will hinge critically on being able to satisfy the Environment Agency that a suitable design for the drainage channel can be achieved along with suitable safe access/egress in times of flood. To date this has not been demonstrated.

1.62 From the above it is concluded that, whilst the principle of developing the site for housing purposes is established, it has not been demonstrated, based upon robust, up to date evidence, that residential development of the site is deliverable. This is compounded by the repeated permissions for nearly 30 years. The proposed allocation is therefore not in compliance with paragraph 182 of the NPPF.

AP 83 Old coach depot, Mitcheldean- Housing Allocation (Site ID No 65)

1.63 The site of 0.4ha is a former coach depot and is proposed to be allocated for 12 homes. Access will be via St Michaels Close which is a narrow, quiet close. The site has been vacant for an extensive period of time and has not come forward for redevelopment. It therefore cannot be assumed that the site is available for development. The site does not benefit from planning permission for its development for housing.

1.64 Given the above, there is no robust, up to date evidence to demonstrate that housing will be delivered on the site over the next five years, or indeed the Plan period to 2026.

AP 84 Former George Hotel, Mitcheldean – Housing Allocation (Site ID No 77)

1.65 The site is the existing George Hotel which is a large vacant public house within the centre of Mitcheldean. Conversion of this property is likely to face the same internal design issues as per the Kings Head, Coleford. There is an advertised tenancy opportunity for the public house therefore the property is not genuinely available now for housing development. The draft Allocations Plan policy requires the retention of the barns and site and it states that retention of the George Hotel itself is desirable. The site does not benefit from planning permission.

1.66 Given the above there is no certainty over the acceptability of converting and developing the site for housing and therefore no robust, up to evidence that demonstrates that the entire draft allocation can be delivered within five years is available. The proposed allocation therefore does not comply with paragraph 182 of the NPPF.

AP 87 The Victoria Hotel, Newnham on Severn and land adjoining (Site ID No 82)

1.67 The site comprises the Grade II listed former Victoria Hotel and extends to 0.35ha. The site also includes an adjoining garage (Victoria Garage). The same issue regarding internal design of the property is likely to apply as per the George Hotel in Mitcheldean and the Kings Head in Coleford, although to a greater degree given that the building is Grade II listed. The site lies within the Conservation Area and there is a large mature tree in the rear of the property. The site does not benefit from planning permission.

1.68 Accordingly, there is no robust, up to date evidence that demonstrates that these concerns can be overcome therefore it is unclear whether the entire draft allocation can be delivered in the Plan period to 2026.

AP 88 Land North of Newnham on Severn and adjoining Unlawater Lane (Site ID No 81)

1.69 The site proposed to be allocated extends to 2.2ha and is proposed to deliver about 40 homes. The Council considers that 20 homes could be delivered on site within 5 years. The site does not benefit from planning permission. The draft Allocations Plan identifies that vehicular access is required to be taken from the A48 as Unlawater Lane is a narrow lane with no pavements. The 2013 Trajectory also identifies that the site would not be completed within 5 years.

1.70 Irrespectively, the A48 is a major highway with a 50 mph limit on the site’s eastern boundary. Furthermore, the eastern boundary of the site is lined by a large mature hedge with large mature trees and is within the Newnham Conservation Area. To create the access it is likely that a significant length of the mature hedge line/trees would need to be felled. Felling these trees could have a significant adverse impact on the rural edge and landscape setting of the site, of Newnham on Severn and indeed the character and appearance of the conservation area.

1.71 Accordingly, there is no robust, up to date evidence that demonstrates that these concerns can be overcome therefore it is unclear whether the entire draft allocation can be delivered in the Plan period to 2026.

AP 89 Land adjoining A48 and Bigstone Meadow, Tutshill (Site ID 83)

1.72 This site is dealt with in detail within the main representations therefore is not addressed again here.

AP 90 The Elms, Sedbury Lane, Sedbury (Site ID 84)

1.73 This site is dealt with in detail within the main representations therefore is not addressed again here.

AP 91 Land adjoining Miners Arms, Sling – Housing Allocation (Site ID No 23)

1.74 The site was allocated in the Forest of Dean Local Plan as Policy R(F) Sling (3) for 15 dwellings. It is proposed to be allocated in the draft Allocations Plan as AP91 Land adjoining Miners Arms, Sling.

1.75 Therefore, despite the Local Plan allocation being in force since 2005, the site has not been developed. Additionally, outline planning permission was previously sought for the erection of 23 homes on the site (LPA Ref P1727-08). This was refused by the Council on 12th February 2010. An earlier application for the same form of development was also refused by the Council. No planning appeal has been recorded and no new applications have been made.

1.76 Given the above there is no robust, up to date evidence that there is a realistic prospect that housing will be delivered within 5 years, or indeed the remainder of the Plan period to 2026. Therefore the proposed allocation does not accord with paragraph 182 of the NPPF.

AP 95 Whitecroft Scovill (Site ID No 85)

1.77 The site of 3.5 ha is proposed for mixed housing (30 homes) and 2.5ha of employment development, of which 1ha has to be provided before the completion of the housing site. The Council considers that 15 homes could be delivered within the five year period. The site consists of a large factory occupied by Prim Fashion UK which is still operational. The site is therefore not genuinely available for residential development now. Accordingly, there is no robust, up to date evidence that the identified number of homes can be delivered in the Plan period therefore the proposed allocation fails the tests set out in paragraph 182 of the NPPF.

AP 96 Housing Site Ash Way (Site ID No 66)

1.78 The site of 0.4ha is proposed to be allocated for 12 homes and access is proposed from the Main Road or from Ash Way, which is either through a private dwelling or through a private garden respectively. The site does not have planning permission. Given that access is unclear, there is no robust, up to date evidence that the site is deliverable and therefore the proposed allocation does not comply with paragraph 182 of the NPPF.

AP 97 Netherend Farm, (Site ID No 24 and 79)

1.79 The site benefited from full planning permission for the refurbishment of the existing farm house and erection of 20 homes with associated works (LPA Ref 25/01/2007), approved on 30th June 2011. Condition 1 of the planning permission requires the commencement of works within 3 years of the date of the permission. Works have not commenced therefore the planning permission has expired.

1.80 The planning permission was subject to viability issues and secured a reduced affordable housing provision. However, the approved development was not attractive to the market as it was not viable. The site is proposed to be allocated within the draft Allocations Plan for up to 36 homes on an enlarged site of 1.2 ha (Draft Allocations Plan Ref: AP97).

1.81 As a result there is no robust, up to date evidence that the site can deliver homes within the next five years at the current point in time.

Sites not contained within draft Allocations Plan but included for completeness

1.82 The following contains assessment of some of the sites that the Council is considering are deliverable within five years but are not proposed to be allocated within the draft Allocations Plan. This list is not exhaustive but it demonstrates a number of additional instances, particularly in relation to some of the more strategic sites, whereby robust, up to evidence does not appear to be available, and therefore there are concerns as to whether the number of homes identified can be delivered in the Plan period to 2026. It is considered that these sites do not comply with paragraph 182 of the NPPF.

Cinderford Northern Quarter (Site ID No 3)

1.83 The Cinderford Northern Quarter is a mixed use development proposal set out within the Cinderford Northern Quarter Area Action Plan (AAP) (Adopted February 2012). The AAP identifies the potential delivery of 175 homes in total within the Northern Quarter. The Council does not identify any specific sites. However, the schedule identifies three planning references as identified below:

1.84 Pending Application, 0663/14. A Hybrid planning application comprising demolition of existing buildings and structures and mixed use redevelopment and associated infrastructure and works to include:

i) Full details of new highway infrastructure and improvements including a new link road between the A4136 and Broadmoor Road, associated means of access, earthworks, footpaths, landscaping, service infrastructure and other associated works and improvements; and full details of a new education campus including a building of 7,750 square metres (gross external area) (Use Class D1), associated means of access, car parking, earthworks, footpaths, landscaping, service infrastructure and other associated works and improvements; and

ii) Outline with all matters reserved, apart from access (in part), for up to 195 residential units (Use Class C3); a Hotel (Use Class C1) of up to 3,000 sq m; up to18,800 sq m for employment use (Use Classes B1, B2 and B8) and a Class D1 non-residential institutional use and; associated internal estate roads, earthworks, car parking, footpaths, landscaping, service infrastructure and other associated works and improvements.

1.85 Withdrawn Applications at Steam Mills:

i) P1279/13 for demolition of outbuildings and alterations to existing building with change of use to residential (flats) and shop unit and alterations to access and construction of a terrace of three dwellings.

ii) P1280/13 Outline Application for the erection of 52 dwellings, open spaces, new accesses and associated works. Demolition of existing commercial buildings. Land At Newtown Steam Mills Cinderford.

1.86 The housing sites at Steam Mills subject to the withdrawn applications are existing employment uses or are overlooked by poor quality employment sites. In this present context it is considered that the sites are not suitable for residential development.

1.87 In respect of the pending planning application 0663/14 this is subject to an objection by Natural England in relation to the impact of the proposed development on Lesser Horseshoe Bats and the Special Area of Conservation. This issue has yet to be satisfactorily resolved and is pending an Appropriate Assessment. This issue also prevented the original planned adoption of the Core Strategy and the subsequent Area Action Plan for the Northern Quarter was subject to a legal challenge by the Friends of the Earth. Friends of the Earth has raised objections to the application proposals.

1.88 In addition, the Coal Authority has identified significant issues relating to the level of historic mine workings on the application site and the need for these to be fully investigated and remediated prior to the commencement of development. Based on the present level of information, the Coal Authority has identified that it is not satisfied that the extent and nature of former mine workings at the site is fully understood.

1.89 In respect of the housing within the present undetermined application, development of these is dependent upon the delivery of Phase 1 of the proposed development (i.e. Phase 1 spine road and college). The proposed housing lies within Phase 2. However, to deliver the housing it will be necessary to construct Phase 2 of the Spine Road. Accordingly to deliver housing within Phase 2 the following will be required in the following order:

• Planning permission for the spine road, college and proposed homes, which is presently undetermined (0663/14); • Selecting developers for the proposed development; • Clearance of pre-start conditions; • Undertaking site preparation works i.e. ground conditions, clearance of habitats, and protected species mitigation; • Commencement of development of phase 1; • Delivering phase 1 infrastructure and the college; • Obtaining reserved mattes approval for the proposed housing; • Clearance of pre-start conditions for the approved housing development; • Undertaking site preparation works i.e. ground conditions, clearance of habitats, and protected species mitigation; • Commencement of construction and delivery of homes.

1.90 Given the above it is not considered that it is realistic to anticipate the development of any homes on the site within the 5 year period.

Whites Farm, Cinderford (Site ID No 6)

1.91 The site benefits from full planning permission for the erection of 169 dwellings granted on the 15th July 2010. Bloor Homes is the developer; the site is under construction and being marketed as St Whites. According to Bloor Homes’ website and on site advertising (7th September 2014) there is only one plot remaining. Bloor Homes has advised that it does not have an option to take forward the 2nd phase of this site which accounts for 48 homes. Accordingly there are only 20 homes available on the site.

1.92 Given the above, it is considered that only 20 homes are realistically deliverable on the site in the remaining 5 year period therefore the proposed allocation does not comply with paragraph 182 of the NPPF.

Lydney East MMC (Site ID No 15)

1.93 The site benefits from outline planning permission for “new housing, employment development, open space and associated access roads, footpaths, cycleways and landscaping” (ref: P1336/04/OUT)” granted on 19th February 2010. Condition 3 of the outline planning permission requires reserved matters applications to be made before the expiration of five years from the date of the above permission i.e. 19th February 2015.

1.94 The outline planning permission however cannot be implemented as Conditions 7 and 28 relating to phasing cannot be met as the employment element of the outline planning permission has subsequently been developed for housing as part of the P0886/10/APP development. This situation was confirmed in the Land at Foley Road, Newent appeal decision dated 31st December 2012 (PINS Ref: APP/P1615/A/12/2177029) where the Inspector states at paragraph 27:

Site 14: Lydney East MMC: The existing planning permission (1336/04/OUT) for 590 units cannot be implemented due to a condition which can no longer be met as a result of residential construction on land formerly identified for employment use. The Council submits that part of the site could provide 170 dwellings. The land is contiguous to housing which is under construction and access is available. However, an application to remove the condition which prevents its development, or a fresh planning application, would be necessary. While the Council considers the land to be available, and expects that residential development will follow on from the adjacent construction site, no such application has been made. The need to obtain planning permission does not, in itself, indicate that a site is not available. However, in this instance, taken together with the complexity of the site and its planning history, and the period which has lapsed since outline permission was obtained, there is no clear evidence to show a realistic prospect of the land being developed within 5 years.

1.95 No reserved matters have been submitted. Similarly I cannot identify new applications or a possible variation of conditions 7 and 28. It is asserted in the Inspector’s decision letter above that an application would be required to remove the condition or a fresh application would be required to overcome this. No such applications have been submitted. Whilst the Council has stated that a planning submission is expected shortly, one has not been submitted. It is clear that there are significant deliverability issues which have prevented the development of this site for over 10 years (from date of the original outline planning application). The position has therefore not changed since the Inspector’s assessment contained within the Land at Foley Road appeal decision.

1.96 The outline permission is therefore not implementable, no new permissions have been granted and it is therefore considered that the site is not deliverable within a 5 year period and therefore does not comply with paragraph 182 of the NPPF.

Table 1: Agreed and contested sites comprising the housing supply for the District.

DRAFT LIST OF SITES FOR LAND SUPPLY FODDC

LPA Position Appellant Position

Site ID Allocated in 2005 5yr 10yr 2014 update Planning 5 yr Summary of position No Local Plan reference

1 Blakeney former 17 17 under construction 1822/13 17 goods stn o/l 2009

2 Bream (Woodside) 9 9 permission for 9 0546/13 9

3 Cinderford 80 175 2 parts, HCA application 1280/13, 0 Site does not have planning permission. Northern quarter, considered all deliverable 1279/13, Present application by HCA pending with as allocated in LP by agent, other section 0663/14 significant issues identified relating to Bats accessed from existing Rd and SAC. Significant infrastructure required considered available by prior to delivery of housing within HCA site. agent‐ of a total now in Requirement to appoint developer and excess of 200, 80 commence delivery of homes. Steam Mills considered within 5 years. site subject to flood risk issues as shown on Part of smaller section of EA Flood Map. Sitting tenants on the site. site is within flood zone 3.

4 Cinderford 0 30 no dwellings expected na 0 Nailbridge within five years

5 Cinderford Railway 10 10 assumed available 0256/12 0 Site realistically will only be developed for Tavern Station following appeal decision housing with or alongside redevelopment of Street 10 the Station St, Listers and, Cannop Foundry sites below.

6 Cinderford St 68 68 site covered by existing 0718/11 20 Phase 2 is not under contract to Bloor Whites Farm permissions 0510/13 Homes and it was not contained within the original contract. Bloor Homes is unlikely to be pursuing this site further is not taking up the second phase. Phase 1 (20 units remaining) will be finished therefore 20 homes are contained within the five year housing land supply. 48 homes will therefore remain. There is potential for the site to be sold to another developer. However there are significant hard ground issues, which could be a contributory factor in why Bloor Homes is not pursuing Phase 2

7 Cinderford Station 50 100 agent reply site available 1590/04, 0 Expired planning permission. Requires St Listers see and could be completed , 0183/09 relocation of existing heavy manufacturing above two sites subject to relocation, sale operation. and any remediation of possible contamination. NB owner is in control of land and premises for any remaining relocation that is required and relocation has been partially completed.

8 Cinderford Station 30 30 agent reply available and 0539/08 0 Expired planning permission. Site St Cannop Foundry could be completed subject realistically will only come forward in to revised application conjunction with (as desired by the Council and proposed allocation plan) or following redevelopment of adjoining heavy industrial sites.

9 Cinderford Station 22 22 agent reply all deliverable 0885/10 0 Expired planning permission. Site St Turley Ct and subject to sale: states that realistically will only come forward in Wilce land viability has been an issue conjunction with (as desired by the Council and proposed allocation) or following redevelopment of adjoining heavy industrial sites. Significant viability and contamination issues.

10 Cinderford Valley 76 76 Under construction 1238/12 76 Kier Developments Rd S (inc Abattoir) now 92

11 Coleford Owen 156 156 agent (developer) reply 1167/13 156 David Wilson Homes Farm now 156 under construction all deliverable

12 Coleford Poolway 80 80 agent reply all deliverable na 0 Site does not have planning permission. Farm inside five years Whilst Council states pre‐application discussions have taken place, no guarantee of a planning application, planning permission or subsequent development.

13 Longhope Rectory 0 15 permission valid but agent 0945/11, 0 Gloucestershire Diocese Meadow reply not viable 1975/11

14 Lydney East 0 80 na na 0 Liddington land

15 Lydney East MMC 150 390 owner plans development 1336/04 0 Existing permission cannot be implemented (not Emp land site) with planning submission due to development of housing on the shortly existing permission for employment under a subsequent separate permission. Whilst new application mooted for MMC, this has not been submitted.

16 Lydney East Phase 0 325 Owner reply can deliver 0412/13 0 A (RHL site) but viability has an impact‐ Growth and infrastructure Act appeal allowed. Note this site and Lydney “B” below are considered together capable of providing 192 dwellings in five years.

17 Lydney East Phase 192 672 Appeal under Growth and 1097/08, 28 Complex site that received planning B (RHL site) Infrastructure Act now 1809/13PLANOB permission on appeal 3rd September 2014. allowed which removes Significant issues remain. However, viability constraint. The Appellant giving the benefit of the doubt to acceptable level of the Council that 28 homes could be affordable housing is as delivered within 5 years, although the permitted. This estimate is Appellant remains far from convinced that for Lydney “A” and “B”. this is a realistic prospect in accordance with Footnote 11

18 Lydney Holms Farm 27 27 agent reply available and 1325/06 0 Expired planning permission. Site has deliverable significant ecology issues relating to bats.

19 Mitcheldean Glos 32 32 developer reply all 0086/09 32 Rd available and able to be completed (site u/c)

20 Newent Broad St 9 9 agent reply available and 800/09, 801/09 9 deliverable, may be potential for alternative permission

21 Newent Onslow Rd 27 27 Under construction 0264/10, 27 B West of Bury Bar 1630/10

22 Newent Ross Rd 0 30 na na 0

23 Sling Adj Miners 20 20 owner reply site being na 0 Site does not have planning permission. Arms marketed considered available and deliverable

24 Woolaston inc 21 21 available now (revised 0111/07 0 Site does not have planning permission. The Netherend Dairy larger area proposed in expired planning permission was not viable draft plan) but original site due to S106 costs. as in earlier permission considered available.

Total completions 1076 2421 374 expected on allocated sites

Current sites not allocated in old LP but which have had pp

25 Cinderford 3 8 8 uc 0620/10 8 commercial St 2481

26 Cinderford 52 8 8 agent reply site is available 2461/11 8 Ruspidge Rd and deliverable‐ sale expected inside 12 months

27 Cinderford 97 St 8 8 legally commenced 0125/08 8 Whites Rd Cinderford Bridge

28 Cinderford 0 0 na complete 2019/10 0 Hollydean

29 Cinderford St Johns 8 8 8 under construction 0344/14 8 Parish Hall 2217

30 Cinderford St 18 18 under construction 0678/13 18 Whites Rd Peacock Lane Ruspidge

31 Coleford 12 Fox's 0 0 na‐ site complete 1370/07 0 Lane Broadwell 2320

32 Coleford 25/27 6 6 uc 0667/08 6 Woodgate rd Broadwell

33 Coleford 27‐41 41 41 uc 1160/11 41 Coalway Rd

34 Coleford Dukes 7 7 available according to 1645/12 0 Long standing outline permissions since travel Berry Hill information from owner. 2003. Site is still operational.

35 Coleford Kings 14 14 owner reply available and 1725/07 14 Meade can be completed

36 Coleford Newland 7 7 foundations in place but 0131/11 7 St former WCs site for sale

37 Coleford 6 6 preliminary works 584/12 6 Sunnybank Hse

38 Coleford Tufthorn 0 0 na 1332/11 0 Ave +9

39 Corse Grange Corse 7 7 revised consent 0114/13 7

40 Drybrook Dairy 17 17 agent reply available and 1753/12 17 Site benefits from existing planning Farm outline l 18 deliverable permission. It has been marketed but no 17 net developer is understood to have been appointed. Potential requirement for provision of replacement farm buildings and silage clamp.

41 Dymock Western 20 20 other 1219/12 20 Two Rivers Housing Association on site. Way

42 Hartpury Over Old 0 0 na complete 1194/10 0 Rd 13 total

43 Lydbrook Central 11 11 owner reply available and 0133/10, 0 Outline planning permission was granted on Eng works capable of delivery. Site 0158/08 22nd December 2011. No RM submitted to agreed as available in Foley date and no robust evidence provided to Rd appeal demonstrate availability. Site still operational

44 Lydbrook Former 26 26 agent reply‐ available as 1303/13 0 Historic site, with planning permissions Rothdean site permission dated 2014. dating back to 1985. Significant EA concerns Site cleared, and vacant in relation to culvert running through the some groundworks site. completed.

45 Lydbrook Orchard 0 0 0 0273/10 0 Rd Joys Green 2465 net 2

46 Lydney Cross 6 6 agent reply available and 0255/13 6 Hands Highfield Hill deliverable

47 Lydney Highfield Rd 47 47 Under construction 1089/11 47 Persimmon Homes developing site.

48 Lydney Highfield Rd 110 110 1829/13 110 Site recently resolved to be approved by rear of T & T the Council. No developer associated with site. £830,000 of S106 contributions and 40% affordable housing agreed. Additionally, given the situation in Lydney A/B in relation to viability, and the considerable reduction in Section 106 obligations and affordable housing provision

on those sites, there are significant question marks about the viability of this site. However, the Appellant is forced to accept that 110 homes could be delivered within 5 years, although the Appellant is far from convinced that this is a realistic prospect in accord with Footnote 11 of the NPPF.

49 Lydney land adj 46 46 under construction, 0886/10 46 Kier Partnerships Federal Mogul contiguous with MMC land, above

50 Lydney Pylers way 9 9 2RH scheme under way 0762/12 9 2 Rivers Housing

51 Newent Bury Bar 0 0 uc 0 0 Lane 2532

52 Newent Craddocks 0 0 complete 0 0 Culver St 2452

53 Newent Culver 0 0 complete 0 0 Street

54 Newent Foley Road 120 120 owner considers site is 0181/12 85 As per the owner expectation that only 85 available but estimates homes will be delivered. only 85 dwellings will be delivered‐ being constrained by the market, however the whole site is considered to be available

55 Newent 0 0 na complete 0 0 Whitegates Culver St 13 809 1406

56 Redmarley The 11 11 uc 1550/12 11 Rock

57 Sling Council Villas 0 0 na complete 0 0 2526 +4 of 22

58 Staunton Corse 0 0 complete 0 0 Chartist Way

59 Tibberton 9 9 under construction 0287/13 9

60 Tutshill Highcliff 7 7 agent reply available and 0794/12 7 Beachley Rd deliverable Tutshill 7 09 1932

Sites with 577 577 498 Permission ‐ Not allocated

New sites Note 1. Sites proposed to be allocated in recommended for Draft AP subject to consultation. As per allocation in ADPD NPPF, and appeal decisions, this document and potentially has limited weight and sites should not be available together deemed genuinely available, suitable or with PPS. deliverable. Additional sites.

61 Cinderford Football 50 90 discussions with developer na 0 Requires relocation of football club. Club underway Agreement of football club required and not confirmed.

62 Coleford Bank 49 49 under construction 0438/13 49 Street (Extra Care)

63 Lydbrook Stowfield 25 45 discussions with developer 0 0 Site is a free standing large industrial site in underway AONB, SAC. Significant flood risk issues.

64 Lydney Augustus 25 25 part of a larger site subject na 0 No planning permission. Site presently Way of application, and appeal subject of appeal to be heard late 2014. therefore assumed available.

65 Mitcheldean 12 12 available 0 0 Site has been vacant for several years. Former coach Owner’s position regarding availability of depot the site is not known. Given this we do not believe there is a realistic prospect of delivering housing within 5 year period.

66 Netherend Ash 12 12 allocation in AP 0 0 As Note 1 above. Way

67 Newent Watery 30 30 valid consent 1513/13 30 Lane

68 Tutshill/ Sed Adj 0 0 not allocated following pp 1792/13 0 Wyedean School refusal (appeal site)

69 Whitecroft Former 40 40 uc total 49 0010/13 40 Vencil Resil O/L permission

Sites approved by June 2014 Cabinet

70 Bream additional 0 6 not assumed within five 0 0 land at Ryelands years Rd/ Highbury

71 Bream off New rd/ 15 30 part of new allocation, 0 0 Application for 14 homes and rugby club High Street application that was P0872/13/OUT withdrawn previously withdrawn now re submitted. Previously recommended for approval.

72 Cinderford Valley 30 45 part of new allocation 0 0 Existing employment site. Requires Road redevelopment of existing employment building and construction of 2,500 sqm of B1 floorspace prior to occupation of first home on site. Existing tenants within some buildings. No planning permission

73 Coleford Kings 12 12 new allocation 0 0 Former public house, proposed for Head conversion. It is an old building with no certainty of delivering 12 homes within existing building ‐ difficulties of internal access, subdivision, provision of suitable habitable rooms and appropriate fire exits etc. No planning permission

74 Coleford 8 8 new allocation 0 0 No planning permission Lawnstone Hse

75 Drybrook 0 40 new no completions in five 0 0 year period

76 Lydney Hill Street 10 25 new allocation 0 0 No planning permission. Site in multiple occupation. Travis Perkins builders yard to rear, parade of retail shops on high street. Site not available now. Travis Perkins understood to have permission to relocate, but have not done so to date.

77 Mitcheldean 18 18 new allocation property 0 0 No planning permission. former George vacant Hotel

78 Mitcheldean new 0 40 no contribution inside five 0 0 site years

79 Netherend Farm 9 9 addition supported by 0 0 No planning permission. additional land owner

80 Newent Cleeve Mill 40 40 land owned by prospective 0 40 Outline planning permission granted in April E Care developer‐ current 2012 (P1034/11). Reserved matters permission required to be submitted by April 2015 but none submitted to date

81 Newnham 20 40 new allocation supported 0 0 No planning permission. Site requires new by owner/developer access onto A48, 50mph section of road. Significant visibility splays required, necessitating felling of large tree lined hedge within Conservation Area and prominent location.

82 Newnham former 20 20 Largely vacant property 0 0 No planning permission. Site is a vacant Victoria Hotel new allocation listed Hotel with adjoining Garage.

83 Sedbury Tutshill 25 45 new proposed allocation 0 0 No planning permission. Site visually very A48 ‐ Bigstone prominent and not suitable. Meadow

84 Sedbury Tutshill 25 50 new proposed allocation 0 0 No planning permission. Site does not Sedbury Lane ‐ The provide suitable vehicle, pedestrian or Elms cyclist access.

85 Whitecroft Scovill 15 30 new proposed allocation 0 0 Existing employment site, occupied by Prym Fashion. No planning permission

Proposed AP Sites 490 761 159

Sub Total 2,143 3,759 1,031

APPENDIX 5

Land adjoining A48 and Bigstone Meadow, Tutshill Key Facts Sheet AP 89 Land adjoining A48 and Bigstone Meadow, Tutshill Landscape and Visual Assessment: concise key facts

Landscape Character: L&V Commentary: National Character Area: 105 ‘Forest of Dean and • The landscape constraints of this 2.6ha of land are Lower Wye. considerable. Landform: • AP89 is on the hillside, elevated above the Rising ground, north east hillside: 45-51mAOD. ‘Unwooded Vale’ Landscape Character Area. Landcover/use: • It is visually prominent being on a hillside. Its visual Arable farmland. prominence is particularly pronounced from land Tree and hedge cover: south of Sedbury Lane and the higher ground around Open field, hedges without trees along boundaries Sedbury Park. with A48 and B4228 Gloucester Road. • Development would also be visually prominent on the approach to Tutshill along the B4228 Gloucester Settlement proximity: Road, from viewpoints to the north, near Old Bishton, Adjoins built edge of Tutshill but is poorly related with and also from Woodcroft. little linkage. • How can the ‘acoustic screening’ identified by Landscape setting: FODDC be formed without the removal of the The landform causes this site to have strong hedgerows along the A48? connections with the countryside beyond its boundaries to the north, east and south east. APPENDIX 6

Land adjoining A48 and Bigstone Meadow, Tutshill Allocations Plan Site Appraisal Sustainability Appraisal Allocations Plan (Pre consultation Draft) July 2014 Appendices Forest of Dean District Council: 23rd February 2012 (Core Document 2) 253

Appendix 6 - Stage 2 Site Appraisals 6

Site Ref: ADPD Site: SHLAA 147 Land at Tutshill A48 Site Area: 2.5 ha 31/318

Housing Employment Retail Unclassified

SO Criteria Results Notes

1A Highway Access + 0 - 1 1B Access to health services + 0 -

3A Proximity to settlement boundary + 0 -

3B Distance to key services + 0 -

Social 3 3C Access to public transport + 0 -

3D Pedestrian Access + 0 -

4 4A Distance to educational facilities + 0 -

5A Agricultural Land + 0 - Grade 2 5 5B Current Land Use + 0 - Economy

6A Site Status + 0 - Greenfield site considered part of the open countryside 6 6B Landscape Impact + 0 - This site slopes down to the A48 and is very prominent location. 7A Impact on biodiversity + 0 - 7 7B Designations + 0 -

8 8A Site affecting an AQMA + 0 - Environment

9 9A Water Quantity/Quality + 0 - Groundwater drinking water at risk

10A Flood risk + 0 - 10 10B Drainage capacity + 0 -

Summary

Assessment of the site indicates some constraints, key ones being agricultural land classification, site status and potential landscape impact and water quantity/quality. APPENDIX 7

Land at The Elms, Sedbury Lane, Sedbury Key Facts Sheet AP 90 The Elms, Sedbury Lane, Sedbury Landscape and Visual Assessment: concise key facts

Landscape Character: private property and garden and farmland of more National Character Area: 106 ‘Severn and Avon Vales’. than one field but with an unresolved northern boundary. Part of the northern boundary is defined by Landform: a field hedge and part is a line drawn across another Comparatively low lying land below the 40m AOD field with little containment. contour. Gradients have an orientation away from the village towards the countryside to the east. L&V Commentary: Landcover/use: • The landscape constraints of this 2.4ha of land are Private residence and garden – elm trees now gone, considerable. plus farmland. • The Sedbury Lane eastern edge is reliant as a future Tree and hedge cover: edge of settlement on two thin hedge lines. The Open field with poor and denuded hedge lines to the sloping ground will orientate and almost ‘present’ west and south, ornamental trees within the private the new housing towards the countryside and not garden. towards the settlement.

Settlement proximity: • It is visually prominent from viewpoints in the public Adjoins built edge of Sedbury at Park View and Tylers and private domain at the edge of the village. Way, and adjoins the edge of Grahamstown Road • Development would sit against the industrial units Employment Area. within the Grahamstown Road Employment Area. Landscape setting: There are issues of conflict in terms of the landscape The landform is not the dominant element, the site is amenity against these very utilitarian industrial an unconnected assemblage of disparate elements: buildings. The Elms site has little amenity in terms of landscape asset. APPENDIX 8

Land at The Elms, Sedbury Lane, Sedbury Allocations Plan Site Appraisal Sustainability Appraisal Allocations Plan (Pre consultation Draft) July 2014 Appendices Forest of Dean District Council: 23rd February 2012 (Core Document 2) 257

Appendix 6 - Stage 2 Site Appraisals 6

Site Ref: ADPD 313 Site: Land off Sedbury Lane, Sedbury Site Area: 2.4ha

Housing Employment Retail Unclassified

SO Criteria Results Notes

1A Highway Access + 0 - Access off Sedbury Lane, Class 3 Road 1 1B Access to health services + 0 -

3A Proximity to settlement boundary + 0 -

3B Distance to key services + 0 -

Social 3 3C Access to public transport + 0 -

3D Pedestrian Access + 0 -

4 4A Distance to educational facilities + 0 -

5A Agricultural Land + 0 - 5 5B Current Land Use + 0 - Economy

6A Site Status + 0 - 6 6B Landscape Impact + 0 -

7A Impact on biodiversity + 0 - 7 7B Designations + 0 -

8 8A Site affecting an AQMA + 0 - Environment

9 9A Water Quantity/Quality + 0 -

10A Flood risk + 0 - 10 10B Drainage capacity + 0 - Area Susceptible to Surface Water Flooding

Summary

Preliminary assessment indicates a number of contraints, primary ones being highway access, site status and drainage capacity. APPENDIX 9

Land at Beachley Road, Sedbury Allocations Plan Site Appraisal Sustainability Appraisal Allocations Plan (Pre consultation Draft) July 2014 Appendices Forest of Dean District Council: 23rd February 2012 (Core Document 2) 255

Appendix 6 - Stage 2 Site Appraisals 6

Site Ref: ADPD Site: Land at Beachley Hill, Beachley Road, Sedbury Site Area: 7.4 ha 218/222

Housing Employment Retail Unclassified

SO Criteria Results Notes

1A Highway Access + 0 - Access off A48 and Beachley Road 1 1B Access to health services + 0 -

3A Proximity to settlement boundary + 0 -

3B Distance to key services + 0 -

Social 3 3C Access to public transport + 0 -

3D Pedestrian Access + 0 -

4 4A Distance to educational facilities + 0 -

5A Agricultural Land + 0 - Part Grade 2 5 5B Current Land Use + 0 - Economy

6A Site Status + 0 - 6 6B Landscape Impact + 0 -

7A Impact on biodiversity + 0 - 7 7B Designations + 0 -

8 8A Site affecting an AQMA + 0 - Environment

9 9A Water Quantity/Quality + 0 - Groundwater Drinking water probably at risk

10A Flood risk + 0 - 10 10B Drainage capacity + 0 - Less susceptible to surface water flooding

Summary

Assessment of the site indicates few constraints, key ones being site status, landscape impact and water quantity/quality.