HILL CONSERVATION GROUP an association of nine parish councils established in 1989 to safeguard the natural and built environment of and its villages

JCS Team Municipal offices Cheltenham GL50 9SA

Email: temporaryjcs@.gov.uk 14 August 2014

Dear sir or madam,

GLOUCESTER-CHELTENHAM-TEWKESBURY JOINT COES STRATEGY PRE-SUBMISSION DOCUMENT, JUNE 2014.

RESPONSE BY BREDON HILL CONSERVATION GROUP

Bredon Hill Conservation Group is an association of nine parish councils established some 25 years ago to safeguard the natural and built environment of Bredon Hill and its villages. A number of the policies in this strategy will have a significant and direct impact upon our member parishes; in particular Bredon, , and Beckford.

The BHCG comments are intended to centre on the robustness of the pre- submission plan and its conformance with national planning policy as well as other legislative requirements.

Policy SP2; Distribution of New Development

The JCS proposes to increase the number of dwellings in Tewkesbury Borough by approximately 23% from 36,100 households to 44,477 households; an actual increase of 8,377 households. SP2 determines that the 8,377 homes will be accommodated ‘elsewhere within Tewkesbury Borough’ (not within either the Gloucester or Cheltenham urban extensions). Of this number, 1,860 will be in Rural service Centres with a further 752 in Service Villages. This suggests that the intention is that Tewkesbury town wider area will accommodate the remainder (i.e. 5,765 new homes). Tewkesbury town, according to the 2011 census data has approximately 9,00 households, this envisaged number will overall growth, within the period, of 64% i.e. two thirds!

BHCG believes that such rapid expansion is unsustainable so making SP2, in this aspect, unsound. Under NPPF paragraph 7, there are three dimensions to sustainable development: economic, social and Please address correspondence to: B.H.C.G., Potenza, Chapel Lane, Kinsham, Tewkesbury, GL20 8HS [email protected]

Ashton-under-Hill, Beckford, Bredon, Eckington, Elmley , Kemerton, , Overbury environmental. The additional, nearly 6,000, homes will be detrimental to the social role of sustainability as the local community will lose a sense of its own identity. Further, the economic benefits of new house driven economic growth should be set against the economic, environmental and social costs incurred by increased road congestion.

It is broadly accepted that new housing at Tewkesbury town will inevitably lead to an increase in commuting as well as travel for retail and leisure so placing strain on the highways network where the A46 junction with the M5 (junction 9) motorway already suffers severe peak time congestion. Delays caused by congestion are economically and environmentally damaging and socially disruptive.

Both the draft SWRSS (4.2.45, page 70) and the Panel Report (4.3.11, page 91) state that Tewkesbury/Aschurch, as a location for significant additional housing, is unsuitable because the existing levels of commuting are unsustainable. The JCS Key Questions confirms that ‘Only 40% of the Tewkesbury workforce lives and works within the Borough boundary, with many commuting to Gloucester and Cheltenham, or outside the Joint Core Strategy area to Worcester or ’. This is confirmed in CCHPR’s The new household Projections Final Report, May 2013 which states ‘at present there is net commuting into Gloucester and out of Tewkesbury’.

The relative lack of retail and employment opportunities in Tewkesbury town is illustrated by policy SD3 retail hierarchy. This policy allocates 821 sq. m net of comparison goods floor space capacity to Tewkesbury town over the plan period compared to the 69,997 sq. m allocated to Cheltenham; an 85 times greater allocation.

Policy SD2: Employment

Policy SD2 iv states ‘Employment-related development will be supported; in the wider countryside when it is: located within or adjacent to a settlement and of an appropriate scale and character’. This policy, BHCG believes, should be qualified to make it clear that such development will only be supported where it is demonstrated to be compliant with district and neighbourhood plans. In the absence of such qualification the policy is flawed because it amounts to a presumption in favour of development in the open countryside which could lead to large scale development in unsuitable locations at the margins of large settlements.

Policy SD10: Biodiversity and Geodiversity

Policy SD10 (clauses 4 and 5) aims to prevent detrimental development within nationally and locally-designated sites without addressing the potential for harm to such sites from nearby development. It can be the case that the biodiversity of an important site could be seriously harmed Please address correspondence to: B.H.C.G., Potenza, Chapel Lane, Kinsham, Tewkesbury, Gloucestershire GL20 8HS [email protected]

Ashton-under-Hill, Beckford, Bredon, Eckington, Great Comberton, Kemerton, Little Comberton, Overbury by the development of neighbouring housing or employment sites. As drafted, the policy fails to comply with NDPF 109, 110 and, in particular, 113 which states that policies should be set for development ‘affecting’ protected wildlife sites.

Policy SD11: Residential Development

Policy SD11 Clause4.ii.states ‘Housing development on other sites will only be permitted where: it is infilling within the existing built up areas of cities, towns and villages’. This policy, as drafted, does not make clear that infilling development will not be permitted unless it is also in accordance with district and neighbourhood plans. In the absence of this qualification this policy is unsound as it is likely to result in development in locations which are recognised by the hierarchy of settlements as being relatively unsustainable.

Policy SA1: Strategic Allocations Policy – Site A8 – MOD Site at Aschurch

BHCG notes that the detailed requirements accompanying Policy A8 in the JCS draft for Consultation, October 2013, have been removed, thus rendering policy SA1 Clause 3 insufficient in detail to cover concerns which are specific to this site. While supporting the principle of this policy, without the protection which was built into policy A8, BHCG does not consider Policy SA1 to be robust.

In particular, BHCG notes that the site is located within 1.25 miles of the AONB so causing concerns as to the negative impact on views from Bredon hill which is within the AONB. Such impact could be eased by increasing the width of the proposed green infrastructure to a minimum of 50 metres. If this green infrastructure took the form of native woodland, it would significantly screen the site from the AONB as well as contributing towards the biodiversity and green infrastructure intent of the strategy. It should be noted that this site is immediately adjacent to the Cotswold Scarp Nature Improvement Area, and that a strip of woodland in this location would meet the purposes of the NIA.

BHCG also has concerns as to the effect of traffic generated by the addition of between two and three thousand houses so close to the AONB. For Policy SA1 Site 8 to meet the test of soundness it should set out effective measures to restrict ‘rat-running’ through the AONB villages of Beckford, , Overbury, Kemerton and Westmancote. This could be achieved by preventing direct vehicular access from the site onto Aston Fields Lane which is narrow and unsuitable for significant levels of vehicular traffic.

Please address correspondence to: B.H.C.G., Potenza, Chapel Lane, Kinsham, Tewkesbury, Gloucestershire GL20 8HS [email protected]

Ashton-under-Hill, Beckford, Bredon, Eckington, Elmley Castle Great Comberton, Kemerton, Little Comberton, Overbury Policy SA1 Site 8 also needs to mitigate the serious impact it could have on the important ecology of the adjacent Carrant Brook vale, where there are nationally important breeding populations of wading birds as well as of more than twenty-five UK Biodiversity Action Plan ‘priority species’ of bird and mammal. Many of these are highly sensitive to human disturbance. Without such mitigation, Policy Sa1 site 8 does not comply with NPPF paragraphs 109,110 and 113.

Yours faithfully

Allan Scott

Secretary Bredon Hill Conservation Group

Please address correspondence to: B.H.C.G., Potenza, Chapel Lane, Kinsham, Tewkesbury, Gloucestershire GL20 8HS [email protected]

Ashton-under-Hill, Beckford, Bredon, Eckington, Elmley Castle Great Comberton, Kemerton, Little Comberton, Overbury