Contents Introduction 2 1a) Flooding and Sewerage: Planning 6 1b) Flooding and Sewerage: Fairford 9 2) Transport Assessment 16 3) Education 22 4) Employment 24 Conclusion 28 Appendices Appendix 1 Letters and emails 30 Appendix 2 Maps 48 Appendix 3 Other documents referred to in the submission 54 Appendix 4 Minutes of Meetings 56 Appendix 5 Extracts from Archive Records 83 Appendix 61 Environment Agency Fairford Flood Report 2008 87 Appendix 7 Fairford Forward Traffic survey Results 130 Appendix 82 Ground Water Levels 141 Bibliography 142 1 The original numbering of this paper remains unchanged and so does not follow the sequence of this document 2 The data in this appendix has been sent as a separate file, ‘2213318 Appendix 8’ Introduction3 The National Planning Policy Framework - Communities and Local Government Committee Section 4 21 December 2011 ▪ Sustainable development is development that meets the needs of the present without compromising the ability of existing communities and future generations to meet their own needs. It is central to the economic, environmental and social success of the country both that these three aspects of development are addressed positively and equally and that planning both serves to protect and to enhance and add value to the environment. This is the core principle underpinning planning. ▪ Policies in plans and decisions on development should be assessed against the principles that the nation and areas within it should live within their environmental limits; should achieve a sustainable economy and should seek to ensure a strong, healthy and just society. Context Fairford is a small town in the Cotswolds which has been growing slowly but steadily since the Second World War4. Over the years we have accepted the inevitability of development and have welcomed the new residents that new housing has brought. However, the gradual expansion in housing over the past half century has not been matched by improvements to the infrastructure of the town and it is this failure to modernise and improve many of the facilities over time that makes further development unsustainable. At the moment, even before recent developments of over 170 new houses are complete, Fairford is exceeding the environmental limits of the existing infrastructure. The Case We fully support the Cotswold District Council (CDC) reasons for refusal of this application. There is no doubt that the entrance to the town and the effect on the Grade 2 listed Burdocks would be highly detrimental. The emerging local plan requires that Fairford ‘will retain its green character’5 but the houses under construction (Bloor and Linden Homes) to the north of the A417 have already had a damaging effect on the entrance into the town; were the Gladman proposals to be approved, the harm would be compounded, and the rural entrance to an old, medieval market town would be destroyed – irrevocably. As our MP, Geoffrey Clifton-Brown has written, ‘it would be a tragedy for the Nation if the level of development in the Cotswolds becomes 3 Please note that all the page references in these footnotes refer to the original document number, not the digital, pdf scrolling number 4 See Appendix 2, Maps, 2.1 A series of maps showing the development of Fairford, p. 48 5 Emerging Local Plan: Second Issues and Options Paper, 6.4, para. 6.26. unsustainably overdeveloped because the damage done will be impossible to reverse.’6 The risk of damage to the quality of the entrance to the town has been tacitly acknowledged by CDC in that they have not included the site in their SHLAA and it is well beyond the development boundary of the town. However, significant though they are, these reasons do not include any consideration of the fact that the development is simply unsustainable, and in this respect the CDC has failed in its duty to protect the town from unsustainable development. A series of applications for large developments have come before the CDC Planning Committee and no account whatever has been taken of the cumulative effects of so much development over such a brief period of time, not only on the capacity of a community to absorb so many new residents in such a short period of time but also on the capacity of a creaking infrastructure physically to support the needs of such an enlarged population. The town has, quite simply, outgrown the existing infrastructure and is unable to support this additional housing. It is certainly the case that this development will compromise the ability of our existing community and of future generations of Fairfordians to meet their own needs. Fairford in the Emerging Local Plan7 Option 1. Fairford is identified as a key local service centre8, after Cirencester (1) then after Tetbury, Moreton-in-Marsh, Bourton-on-the-Water (2) – a third tier town Option 2. Fairford is identified as a key local service centre, after the main towns, Cirencester, Tetbury, Moreton-in-Marsh, Bourton-on-the-Water. Option 3. Fairford is identified as a minor service centre9 together with Lechlade, Northleach, Stow-on-the-Wold and South Cerney, after Cirencester (1) then after Tetbury, Moreton-in-Marsh, Bourton-on-the-Water, Chipping Campden (2) In none of these cases could Fairford be described as a principal settlement10 in any usual understanding of the word ‘principal’11. Infrastructure12 Systems for sewage treatment and disposal Historically Fairford has suffered from flooding, from river, sewers/drains and surface water. The personal, social, and economic consequences of flooding are severe and widespread, and must be given due consideration in all planning matters. The sewage flooding risk in Fairford has been officially acknowledged for several years to be at an unacceptable ‘significant risk’ level. 6 Letter to Nick Boles Esq MP – Appendix 1: Letters and emails 1.1, p. 30 7 Whilst it is accepted that the Emerging Local Plan has not yet been adopted, the documents supporting the Gladman application have made extensive use of the plan and we therefore consider it legitimate to do the same. 8 Emerging Local Plan, Settlement Hierarchy Topic Paper, Section 5.16 9 Ibid, Section 5.32 10 Cotswold District Council, Statement of Case. Section 8a Officer’s Assessment: Housing land supply and the principle of the development proposed in this location, p. 16 11 Chambers Dictionary. Principal = ‘1. Highest in rank or importance 2. Chief, main’ 12 For the purposes of this paper, ‘infrastructure’ does not include gas, electricity or telecoms The current system was installed in the 1943 in preparation for the then new Fairford Air Base. This was a combined sewage and surface water system in which both sewage and surface water from the existing town drain into the same system. The main sewers now lead to pumping stations at Horcott in the west and Moor Farm in the east. From there it is pumped uphill to the treatment plant near the RAF base. After many sewage- flooding problems, the Moor Farm pumping station was upgraded by Thames Water in 2006 to cater for a population equivalent of 4222. In the major flood incident of 2007 the system failed, and there was extensive sewage flooding which has been repeated in subsequent years. Population is already 3500 - 4000, and with the 175 houses already under construction, will exceed the limit. Thames Water has agreed that, ‘the existing waste water infrastructure cannot accommodate the needs of the proposed development.’13 (see Section 1) Mains Water It is accepted ‘the network has insufficient capacity to supply the proposed development’14. A sufficient supply of clean water is surely a basic right. Consequences of a lack of capacity to deliver mains water include reduced pressure and even intermittent flow; already some properties suffer from low water pressure. Significant engineering would need to be undertaken to improve capacity. The inadequate supply of water would affect schools as well as residential housing. (see Section 1) Transport The A417 runs through the centre of the town, the route unchanged since medieval times. Narrow, at times down to single lane traffic, it cannot be improved. Plans (and a route) for a by-pass were abandoned in the 1990s, the land sold off. The only possible by-pass route now is the Spine Road to the A419 which, however, has its own problems: it is unimproved over long stretches; there is no prospect of weight restrictions through Fairford; and lorries coming from the west would still need to travel through the town. (see Section 2) It should also be noted that all development tends to follow the line of the main road in an undesirable ribbon development pattern since the area to the north of the town is AONB, the Ernest Cook Trust estate and to the south is floodplain. Primary School The present school was built in the 1980s, just before a major development in the north of the town. It replaced a village school which had grown to such an extent that it was largely a collection of portacabins. In the past thirty years pupil numbers have continued to increase and it is now full to capacity and residency in Fairford is no guarantee of a place at the local school. (see Section 3) Surgery The present surgery moved from a residential building in the 1990s. It forms part of a small development, Keble Lawns. As such it is hemmed in on all sides with no physical capacity for expansion. Parking, always limited, is at critical levels and the overflow now causes a significant problem for residents of the estate. Since its construction two sizeable sheltered developments have been built in the town. Although NHS England have stated that the surgery is able to cope with the increase in population which would result from all the proposed developments, repeated Freedom of Information requests 13 Cotswold District Council, Statement of Case.