Land at Cloverlea Barn, Wickwar Road, Kingswood, Gloucestershire

LAND AT CLOVERLEA BARN, WICKWAR ROAD, KINGSWOOD, GLOUCESTERSHIRE

Stroud District Council Application Reference: S.16/0629/FUL

Residential development of 61 Dwellings with supporting infrastructure and enabling works including new vehicular access off Wickwar Road (including the demolition of 24 Wickwar Road), public open space, landscaping and drainage infrastructure. Cloverlea Barn Wickwar Road, Kingswood, Gloucestershire, GL12 8RF.

On Behalf of Kingswood Parish Council

20 June 2016

Table of Contents

1. Executive Summary ...... 2 2. Introduction and Instructions ...... 2 3. Relevant Policy and Legislation ...... 3 4. Strategic Growth and Development Options ...... 5 8. Landscape, Design and Character ...... 12 9. Conclusion...... 13

1. Executive Summary

1.1. It is considered that the planning application S.16/0629/FUL for the development of 61 dwellings and enabling works at the Cloverlea Barn site, Wickwar Road, Kingswood, Gloucestershire, GL12 8RF does not represent sustainable development in accordance with national policy and that it is a departure from the up to date statutory development plan for Stroud District Council, The Local Plan, 2015 (SDLP). The planning application S.16/0629/FUL conflicts with the SDLP policies below:

 Policy CP2 Strategic Growth and Development Locations  Policy CP3 Settlement Hierarchy  Policy CP4 Place Making  Policy CP5 Environmental Development Principles for Strategic Sites  Policy CP8 New Housing Development  Policy CP9 Affordable Housing  Policy CP15 Quality Living and Working in the Countryside  Policy ES7 Landscape Character  Policy ES15 Provision of Outdoor Play Space

1.2. The application S.16/0629/FUL is also a departure from the emerging Kingswood Parish Council Neighbourhood Plan.

 Policy SL1 Kingswood Settlement Development Limits Boundary  Policy LA1: Landscape Character and Locally Importance Views

2. Introduction and Instructions

2.1. Persimmon Homes Severn Valley submitted a major planning application S.16/0629/FUL for the development of 61 dwellings (including the demolition of 24 Wickwar Road), public open space, landscaping and drainage infrastructure in March 2016. The S.16/0629/FUL application is at Land at Cloverlea Barn Wickwar Road, Kingswood, Gloucestershire, GL12 8RF. The site is classified as agriculture. Kingswood Parish Council has instructed Troy Planning & Design (Troy Hayes Planning Limited) to support its representation in respect of the above planning application S.16/0629/FUL. Troy Planning & Design are experienced planning practitioners. Our work more widely includes involvement in the preparation of a number of Local and 2

neighbourhood plans, the preparation and submission of planning applications and planning appeals for a range of clients. In this case, Troy Planning & Design has a very good knowledge of the planning context of Kingswood Village having assisted Kingswood Parish Council in providing representations previously on other major proposals and in the advancement of its neighbourhood plan.

3. Relevant Policy and Legislation

3.1. The following schedule of policies, guidance and legislation provides a (non-exhaustive) list of matters considered specifically relevant to determining the application:

National Planning Policy Framework (2012)

3.2. This National Planning Policy Framework (NPPF) sets out that the statutory status of the development plan is the starting point for decision making. Proposed development that accords with an up-to-date Local Plan should be approved, and proposed development that conflicts should be refused unless other material considerations indicate otherwise.

3.3. NPPF paragraph 15 sets out all plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally.

3.4. NPPF paragraph 17 outlines that planning authorities should take into account the different roles and character of different areas and actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable.

3.5. NPPF paragraph 31 sets out that LPAs should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development.

3.6. NPPF paragraph 50 sets out the LPAs should plan for a mix of housing based on current and future demographic trends.

3.7. NPPF paragraph 109 sets out that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes.

Stroud District Local Plan (2015)

3.8. On 19th November 2015, Stroud District Council (SDC) adopted a new Local Plan for the Stroud District. The SDLP provides a positive planning policy framework for appropriate growth up to 2031. Though not an exhaustive list, below sets out the key planning policies relevant in determining this planning application.

• Policy CP2 Strategic Growth and Development Locations • Policy CP3 Settlement Hierarchy • Policy CP4 Place Making • Policy CP5 Environmental Development Principles for Strategic Sites • Policy CP8 New Housing Development • Policy CP9 Affordable Housing • Policy CP15 Quality Living and Working in the Countryside • Policy ES7 Landscape Character • Policy ES15 Provision of Outdoor Play Space

Emerging Kingswood Neighbourhood Plan

3.9. The Kingswood Parish Council is currently preparing its Neighbourhood Plan and was submitted to Stroud DC on 14th April for consultation. This is a material consideration in current planning decisions. A key policies relevant to this application is set out below.

 Policy SL1: Kingswood Settlement Development Limits Boundary  Policy LA1: Landscape Character and Locally Importance Views

Stroud District Council Key Housing Evidence

 Stroud District Council, The Strategic Housing Market Assessment (SHMA), 2014  Stroud District Council, Strategic Assessment of Land Availability (SHLAA) 2011  Stroud District Council, Strategic Assessment of Land Availability (SHLAA) Final Methodology, 2016  Settlement Role and Function Study, December, 2014  Inspector Report, Local Plan, 2015 Examination, November 2015  S.14/1927/OUT. Chestnut Park. The development proposed is described as `outline planning application for construction of up to 59 dwellings, public open space,

landscaping and associated works. 2014. Refused. 2015. Appeal. APP/C1625/W/15/3011370. February. 2016.

4. Strategic Growth and Development Options

4.1. SDC has consistent trends in housing delivery. The Inspector, in November 2015, agreed with SDC that a 7.03 years’ supply could be demonstrated, using a 5% buffer as there was no evidence of persistent under delivery of housing. (IR, para. 56-57, 2015). The SLAA, 2011 provided up to date evidence on how the SDC housing need was going to be addressed in the plan period up until 2031 at the examination. SDC clearly illustrated they can deliver an adequate amount of housing supply in plan period. Subsequently, the SDLP was found sound in November 2015 further to an independent examination. The SDLP sets out a clear, evidence based up to date strategy for housing growth which must be adhered to. The Inspector concluded that ‘In the context of a Local Plan, which fully meets the identified housing requirement, to allow unrestricted development outside existing settlement limits could undermine the established strategy of managing growth in the district.’ (IR, para. 66, 2015).

4.2. S.16/0629/FUL is a major planning application for 61 new dwellings in an area not identified as a growth location. Proposals at Cloverlea Barn Wickwar Road, Kingswood, Gloucestershire, GL12 8RF was put forward for consideration as an omission site during the SDLP examination in 2015. It was the only omission site put forward at Kingswood. The Inspector rejected all omission sites (see para. 209-211 of Inspector’s Report, 2015) on grounds, which included that there is no need to identify any additional or alternative sites to meet housing requirements and that none of the sites performed better than allocations in the Local Plan. It is therefore considered that S.16/0629/FUL is contrary to NPPF para 15 and para 17. The application S.16/0629/FUL does not represent SDC’s strategy for sustainable development (as set out in more detail below) or the distinct character of Kingswood Village. The Inspector specifically supported this principle and detailed boundary of settlement defined limits sets out in the SDLP ‘as a key element of the Plan’s strategy to direct most, new development to sustainable locations at the higher tier settlements; this helps to prevent the uncontrolled expansion and coalescence of settlements and safeguard the countryside from encroachment’ (IR, para. 160, 2015). In addition, the Inspector further noted that ‘In many cases these settlements [Tier 3] have already accommodated significant amounts of development in the past, including earlier within the current plan period...and it is now appropriate to refocus strategic development at the most appropriate and sustainable larger settlements’ (IR, para. 76, 2015).

4.3. Policy CP2 (Strategic Growth and Development Locations) subsequently sets out the appropriate statutory strategy for housing growth for SDC. Policy CP2 sets out that, ‘Stroud District will accommodate at least 11,400 additional dwellings’. Strategic sites are identified in ‘key growth locations’ (see figure 1 below). Policy CP2 also sets out that ‘limited development will take place outside of these designated areas and in accordance with other policies of the plan.’ A major housing scheme at the Land at Cloverlea Barn site is a fundamental departure to the SDLP Strategic Policy CP2. Policy CP2 defines Kingswood Village as ‘a settlement with limited facilities’. Given this ‘limited facilities’ status restricted growth is the policy position over the plan period (up to 2031). The strategy for major housing development is not south but north of the Kingswood Village where there is adequate access to supporting infrastructure, services and facilities (see figure 2 below).

4.4. Kingswood Village under Policy CP3 (Settlement Hierarchy) is a ‘Third Tier Accessible Settlement with Limited Facilities’. In order to control and carefully manage the level of growth Policy CP3 sets out that ‘proposals for new development should be located in accordance with the District's settlement hierarchy. This will ensure that development reduces the need to travel and promotes sustainable communities based on the services and facilities that are available in each settlement. The use of previously developed land and buildings will be encouraged’.

4.5. The application S.16/0629/FUL is a major new housing development and as such represents a departure from Policy CP3. The policy also sets out ‘Third Tier Accessible Settlement with Limited Facilities’, ‘possess a limited level of facilities and services. … They will provide for lesser levels of development in order to safeguard their role’.

4.6. SDLP Paragraph 4.26 sets out that ‘defined settlement development limits’ are shown on the policies map. They are essential to the application of many of the SDLP policies and seek to achieve the following:  to direct development to appropriate and sustainable locations across the District;  to protect the countryside from isolated and inappropriate development;  to ensure that new development is sympathetic in scale and location to the form and character of our settlements; and  to prevent the uncontrolled expansion of settlements and potential coalescence.

4.7. The above defined settlement development limits are to manage growth to ensure that the right level of development goes to the most sustainable locations in the District. The proposed development, S.16/0629/FUL especially when considered within the context of cumulative

growth since 2006 is contrary to the NPPF para 15, para 17, SDLP CP3 and SDLP Paragraph 4.26, which set out clear provisions to control the expansion of settlements. The proposed development would be a significant encroachment into the countryside, and in addition would materially change the character of the village in this location from one of ribbon development to a concentrated urban form.

4.8. Policy CP4 (Place Making), outlines that ‘all development proposals shall accord with the Mini- Visions and have regard to the Guiding Principles for that locality’. Urban sprawl which breaks the current settlement boundary of Kingswood Village and forcibly extends into the countryside south is not part of the strategic vision for SDC, and equally it is not part of its ‘mini-vision’. There is insufficient evidence provided in the S.16/0629/FUL application to illustrate or to justify that any of the criteria of CP4 have been met. It is considered that the proposed S.16/0629/FUL application falls short of the statutory requirements of CP4 in a number of areas. Examples are set out below.

 Under Policy CP4, proposals will be expected to 'integrate into the neighbourhood (taking account of connectivity, be located close to appropriate levels of facilities and services, reduce car dependency, improve transport choice, support local community services and facilities and meet local employment or housing requirements in terms of mix, tenure and type)’.

Figure 1. Stroud District Council, Local Plan, 2015. Settlement hierarchy and development opportunities.

8 Figure 2. Stroud District Council, Local Plan, 2015. Accessibility to key services.

 CP4 part 2 sets out that new development should ‘enhance a sense of place (create a place with a locally-inspired or distinctive character – whether historic, traditional or contemporary – using appropriate materials, textures and colours, locally-distinctive architectural styles, working with the site topography, orientation and landscape features; as well as protecting or enhancing local biodiversity, the historic environment and any heritage assets)’. The development proposals would result in the breaching the settlement boundary of Kingswood Village. This would result in poor integration with the village under the principles of this policy. As opposed to protecting and enhancing the distinctive character S.16/0629/FUL application breaks the current settlement boundary of Kingswood Village to the detriment of the village’s distinctive character.

4.9. Policy SL1 (Kingswood Settlement Development Limits Boundary) sets out the emerging Kingswood Neighbourhood Plan policy position. It outlines that ‘the development of the village of Kingswood shall be focused within the settlement limits boundary as identified on the Proposals Map. The development in this location would be a departure from Policy SL1 of the emerging NDP. It would significantly extend the defined settlement limits of Kingswood Village.

5. Housing Mix

5.1. NPPF para 50 sets out that LPAs should create a mix of housing to meet identified needs. Core Policy CP8 (New Housing Development) requires that new housing development must be ‘well designed to address local housing needs, incorporating a range of different types, tenures and sizes of housing, to create mixed communities’. Policy CP9 (Affordable Housing) outlines that housing proposals should broadly reflect the ‘sizes and types that meet the proven needs of people who are not able to compete in the general housing market’. The application fails to show a balance of housing mix i.e. of two and three bedrooms will be provided under CP8 and CP9. The application therefore is contrary to NPPF para 50, Policy CP8 and Policy CP9.

6. Education Provision

6.1. NPPF para 17 sets out the importance of creating balanced communities, which have access to key services and facilities. This includes education. CP4 outlines that ‘all development proposals shall … integrate into the neighbourhood (taking account of connectivity, be located close to appropriate levels of facilities and services, reduce car dependency, improve transport choice, support local community services and facilities and meet local employment or housing requirements in terms of mix, tenure and type)’. An addition of 61 additional dwellings would significantly increase the demand on facilities and services of the village. There is no evidence of committed infrastructure projects to support 61 new dwellings in the pipeline i.e. education provision.

6.2. Policy CP5 (Environmental Development Principles for Strategic Sites) sets out that proposals should ‘4. have a layout, access, parking, landscaping and community facilities’. Core Policy CP8 (New Housing Development) sets out that new developments must ‘be 1. Be built at an appropriate density that is acceptable in townscape, local environment, character and amenity terms’. The application S.16/0629/FUL is in a location which is already denoted as constrained in respect to key services and facilities such as education (see figures 1 & figure 2 above). School places would be required as a result of this new proposal. There is no current evidence of a future strategy to build a new school or capacity for additional students in a reasonable proximity to this location to absorb such an increase in population irrespective of S106/CIL. As such the application is contrary to NPPF 17 and Policy CP4, Policy CP5 and Policy CP8.

6.3. Kingswood Primary School is a constrained site and does not have any scope for expansion. Jennifer Gillman, Data Support Officer at Gloucestershire County Council confirmed this in her email of 25 May 2016 , which outlines that ‘children emerging from the Charfield Road development are likely to get a place at Kingswood Primary, as it's the closest school, however, as the school is unable to expand, this will then have a knock on effect at Blue Coat Primary. The same circumstances will apply to a new planning consultation received for a potential development at Cloverlea Barn, Wickwar Road, Kingswood. Any S106 funding secured for either of these developments will, therefore, go to Blue Coat Primary’. S106 contributions therefore cannot provide an adequate number of school places to provide for the needs of a new major housing proposal in this location. As set out in figure 1 & 2 above new such critical infrastructure growth is north of Kingswood as this location is completely constrained. (An underlining principle of the Strategic Growth and Development Policy CP2 noted above).

6.4. As such, the Head of Kingswood Primary School submitted an objection to S.16/0629/FUL. Kingswood Primary School ‘formally object to the proposed development of 61 houses at Land at Wickwar Road, Kingswood (S.16/0629/FUL)’. The school does not have the capacity to accommodate the increase in demands for school places. It is stated that ‘the objection is raised solely on the grounds on the lack of capacity at Kingswood Primary School’. It is set out that ‘the school does not and will not have capacity.’ The objection further states ‘the school currently has 101 pupils (with an expectation of 106 pupils from September 2016). The additional estimated 14.75 children from the Chestnut Park (phase 2) appeal equates to a total of 115.75 pupils. As noted from the previous two estates (Tyndale View and Chestnut Park) and the significant increase in pupil generation. … Kingswood Primary School cannot grow due to the limitations and constraints of its site. Increasing the pupil numbers will have a severe impact on the pupils and their leaving potential. Classrooms would be overcrowded, resources overstretched, creativity and physical education would be stifled due to the significant lack of space. At the current time there is insufficient educational infrastructure to support this significant increase in housing growth in the village’.

7. The Local Transport Network

7.1. NPPF para 31 sets out the importance of ensuring that transport infrastructure is adequately provided in new developments. Policy CP8 (New Housing Development) outlines that ‘new housing development must 2. have a layout that supports accessibility by bus, bicycle and foot to shopping and employment opportunities, key services and community facilities or contribute towards provision of new sustainable transport infrastructure to serve the area 3. have a layout, access, parking, landscaping and community facilities that are appropriate to the site and its surroundings; and 5. enable provision of infrastructure in ways consistent with cutting greenhouse gas emissions and adapting to climate change and its consequences’.

7.2. It is considered that the proposed development would be contrary to the principles of NPPF para 31 and Policy CP8 as it is not accompanied by adequate evidence to show adequate supporting infrastructure. There is insufficient evidence in this application that the access road to Kingswood Village at Junction 14 has capacity to cope with 61 additional dwellings.

7.3. Policy CP5 (Environmental Development Principles for Strategic Sites Strategic) sets out that proposals should be ‘3. Be readily accessible by bus, bicycle and foot to shopping and employment opportunities, key services and community facilities; and will contribute towards

the provision of new sustainable transport infrastructure to serve the area, in seeking to minimise the number and distance of single purpose journeys by private cars’. The application S.16/0629/FUL does not provide the necessary evidence to show that it can discharge the requirements of Policy CP5 in regard to transport and access in particular as set out in parts 3 and 5 and it is considered it is contrary to this policy.

7.4. Highways England’s response to SDC on S.16/0629/FUL of the 22 April 2016 sets out that, ‘the application site is not allocated in the SDLP. As set out in the Stroud District Council, December, 2014, Junction 14 is currently operating over capacity in the am peak and near capacity in the PM peak. The junction is forecasted to be operating over capacity in 2031 in both peaks with the Local Plan development traffic’. Highways England later states that, ‘Circular 02/2013 paragraph 22 states that: where proposals are not consistent with the adopted Local Plan then a full assessment of their impact will be necessary, which will be based on the performance and character of the strategic road network as determined by the presumption that the Plan proposals will be fully implemented’.

7.5. The response highlights the degree and extent the S.16/0629/FUL application represents a significant departure from the SDLP and the adverse impacts on the local transport network. Highways England conclude with the endnote that ‘no part of the development hereby approved shall be occupied or brought into use until the improvement scheme to Junction M5 14’ is in place. There is insufficient evidence provided with this application S.16/0629/FUL to show that an adverse impact on Junction 14 would not be incurred. It is considered the scheme would be contrary to NPPF para 31 and Policy CP8 and Policy CP5 in this regard.

8. Landscape, Design and Character

8.1. NPPF para 109 sets out that LPAs should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes. The application S.16/0629/FUL is contrary to Policy CP15 (Quality Living and Working in the Countryside). The above application does not show how the scheme discharges any of the requirements of Policy CP15 for example that it ‘does not lead to excessive encroachment or expansion of development’ and therefore the applications contrary to the development plan in this respect.

8.2. Policy ES7 (Landscape Character) sets out that ‘in all locations development proposals should conserve or enhance the special features and diversity of the different landscape character types found within the District’. The emerging Kingswood Neighbourhood Plan Policy LA1 (Landscape Character and Locally Important Views) also sets out the value of protecting the 12

local landscape character of Kingswood Village. The current landscape character of this area is agricultural. The proposed developed would be located south of the B4060 Wickwar Road. Whilst, there are no designated viewing points at the site the S.16/0629/FUL major housing scheme would be one of the first things that one would see entering the southern gateway to the Kingswood Village. More evidence to demonstrate that S.16/0629/FUL would not have the detrimental adverse impact on the landscape, character and appearance is recommended to justify that this scheme would be acceptable.

8.3. Policy ES15 (Provision of Outdoor Play Space) sets out that proposals for new residential development shall provide appropriate public outdoor playing space. The position from the Public Open Space Officer, Mark Hemming 05 May 2016 on this application, which is available online sets out that the ‘The layout of the development fails to address the following policy: ES15’. Troy Planning & Design concur the proposal fails to meet the requirements of statutory Policy ES15.

9. Conclusion

9.1. It is recommended that the S.16/0629/FUL is refused. The SDLP has been recently adopted in 2015 and full weight should be given to its policies as required by paragraphs 12 and 15 of the NPPF. There is a presumption in favour of sustainable development through the policies contained within the Local Plan in the NPPF and it also requires that proposed development which conflicts with the Local Plan should be refused unless material considerations suggest otherwise.

9.2. In our view the S.16/0629/FUL proposal is a fundamental departure to SDC Strategic Growth and Development Options and is therefore contrary to NPPF para 15 and para 17, Policy CP2 Policy CP3, Policy CP4, Para 4.26 and emerging Kingswood Neighborhood Plan Policy SL1. As noted above, the Inspector for the Stroud Local Plan also concluded that ‘In the context of a Local Plan which fully meets the identified housing requirement, to allow unrestricted development outside existing settlement limits could undermine the established strategy of managing growth in the district’ (IR, Para 66, 2015).

9.3. The S.16/0629/FUL application would have an adverse impact on the local transport network as identified by Highways England and it is therefore considered the scheme would be contrary to NPPF para 31, Policy CP5 and Policy CP8 in this respect.

9.4. The S.16/0629/FUL application also fails to show a balance mix of housing would be provided. The application therefore is considered contrary to NPPF para 50, CP8 and CP9.

9.5. The S.16/0629/FUL is contrary to NPPF 17, Policy CP4, Policy CP5 and Policy CP8 as it would not be able to provided adequate basic level of educational infrastructure as highlighted by Kingswood Primary School.

9.6. It is considered that more evidence would be required to demonstrate the application is in accordance with NPPF para 109, Policy ES7 and Policy LA1 in respect to the protection of landscape character at the southern entrance of Kingswood. Lastly, the application does not provide adequate outdoor play space as defined by Policy ES15.