Final public consultation was in August.
For our response to the consultation, go to the News page
Questioning The Figures
For the twenty years from 2011 to 2031, the JCS have calculated the number of new houses needed, to be between 33200 and 37400.
The JCS have identified 18.500 new houses already available through existing planning permissions,small urban sites and developments in rural areas. For the 10 year period from 2001 to 2011 the population of Gloucestershire increased by 5.7℅. Applying this growth to the housing stock in 2011 would result in 7775 new houses by 2021 and 15,994 new houses by 2031(an average of approximately 780 new houses per year). The JCS have estimated an average requirement of 1730 new houses per year !
This a potential overestimation of at least 17200 houses, more than all the houses proposed for all the new sites combined.
Local MP Laurence Robertson has said the Government has set the bar too high and is forcing councils to grant developers permission to build thousands of houses on Green Belt.In a recent Parliamentary debate Mr Robertson stated the following.
"There is no shortage of housing in Tewkesbury Borough During the last 20 years Tewkesbury has built 7.536 houses
The JCS figures suggest (Cambridge egonometric calculation) 10.900 houses will be needed in the next 20 years This is 45% higher building rate than the last 20 years Also, with Tewkesbury's allocation for housing within this JCS,this number of housing will increase further to 18,800! This means the rate of building will be 150% higher than the last 20years. Why are Gov following a predict provide approach to building
Assessment should be on based on experience and fact."
The Government admit there is no standard methodolgy for assessing future housing need.
Data from the Office of National Statistics (ONS) and the 1961-2011censuses indicates that the occupancy rates (for the JCS area) have flattened out at approximately 2.2-2.4 people/household.
The JSC have chosen to ignore this data and use an interim projection, which experts have warned should only be used over a short term period.
Removing land from the Green Belt for development must be the last resort and kept to the absolute minimum. Future housing need must be based on a more realistic, rigourous and accurate assessment
19,000 houses have already been given planning permission. 55%of the housing need. This is more than 10 years supply of housing. Greenbelt and green fields do not need to be sacrificed yet. (The majority of strategic locations identified in this JCS lie within the Green Belt!)
· The Office of National Statistics is bringing out a new survey next march 2014 which will inform future housing need more accurately. Numbers are expected to be lower.
· Present Housing numbers are flawed It is .not true for example that more people are living alone. Campaign to Protect Rural England is challenging the housing numbers. Is there really a massive housing shortage in the area? There is evidence to suggest that the figures are very over- estimated with top- down target setting
· More evidence is needed from the Strategic Housing Market to make sure evidence for need is totally accurate. The JCS admit this still has to be reviewed
· More traffic and transport modeling needs to be done to make certain infrastructure can cope with an increase in population .Some housing plans are very large scale.
· Developers are land banking (ie holding on to land already given planning permission )and should be made to release land for immediate building
· Other possible areas…Wyeman’s brook Swindon Lane (Wimpy owned) Highnam and other under- developed areas/ /Tesco’s(Ermin Street) Brockworth /40 hectares of brownfield at Cheltenham/ windfall sites.(.sites which come forward, in the future for development eg future possibility of the present site occupied by the entire Invista factory at Brockworth?. Brownfield sites in Gloucester eg Bristol Road, (CPRE states there are brownfield sites available) Land South of Gloucester City.Empty properties? (800.000 throughout the country!) Land banked areas (held on to by developers) Greater numbers of houses allocated to the 15 “ service villages”in the JCS plan, reducing the need for massive, large scale urban extensions. Business parks where land has not been taken up for employment as advocated by National Planning Policy Framework
There is also a duty to co-operate between councils, including those not in the JCS. There are 3 other councils bordering the JCS area that could help towards providing suitable sites .
· Needs to be pressure on the strategy for a sequential release of land for development eg brownfield first / Greenfield/ then as a last resort, GreenBelt . NPPF encourages use of brownfield sites and the protection of Green Belt. “Land allocation should prefer land of lesser environmental value”
· A very substantial number of local councillors consider this JCS is a flawed document and want facts scrutinized before submission in Aug 2014
· Tewkesbury is providing over 50% of development sites within the JCS area
Brockworth should not be a strategic development site for the following reasons
· Historical evidence . a).Brockworth has had 3 Green Belt reviews since 2007
Two out of three regarded the site as making a positive contribution to the Green Belt. The last review rated the site as making no contribution to the Green Belt. There had been no changes in the landscape during this period and criteria of assessment must have been altered. Therefore this is not a fair and balanced review.
b)Tewkesbury Borough Local plan 2007-2011 rated the site as an Important Open Space. “Forming a landscaped edge to the built up area” It was deemed such owing to the fact that it is a valued open space for recreational purposes, wild life, spectacular views of the AONB and for tranquility and sense of place. It is now the last open space with access to the open countryside for the people of Brockworth. It is also an important ‘green lung’ . NPPF 77 advocates identifying these areas and protecting them
There is also an ancient Heritage area central to the proposed site.
The Green Belt site is an important buffer between the A417 and the village.
The land at Brockworth is very productive Grade 3a ‘good quality’ agricultural land, producing barley, wheat, rape seed etc. the latest government initiative states that the country should be more self sufficient in food production.
· Environmental evidence Some of the site lies very close to the AONB and Coopers Hill a world famous AONB site. NPPF states the requirement of taking into account land forms when planning. The land rises to the East of the site and any development will impact directly on the Cotwold escarpment AONB and Coopers Hill. The NPPF recognises the need to ‘protect Green Belt around urban areas and recognise the beauty of the countryside’
· Other evidence . There is a real danger of over- development with regard to Brockworth as a settlement. An extra 1500 houses will increase the population by a half and will render the settlement unsustainable regarding health care, employment , schools and access to open spaces etc. The identification of this site for 1500+ houses means that a settlement the size of a new village will be created on the Green Belt. This will not relate to or be integrated into the existing community of Brockworth, but will lie separate owing to the placement of Horsebere Brook. It will be serviced by its own shops and will cause a huge increase in traffic likely to cause grid-lock and rat-runs through the existing village. There will be serious effects on local road junctions. The massive scale of proposed development is not in proportion to the existing development of the village of Brockworth.
Contrary to Government hopes, not everyone in the new settlement will be using a bicycle. Indeed there is a real danger of the new settlement becoming a commuter suburb and dormitory development with residents travelling to Bristol/ Cirencester for employment.
· There should be a considerable reduction now in the number of housing allocated to Brockworth. There has been a huge amount of building in recent years with the dense housing estate of Coopers Edge still to be completed. (1000 houses)For these reasons, Brockworth should be re-designated as a rural service centre in the JCS plan. Another large scale housing estate will affect the standard of living for existing residents of Brockworth .
The village should not be an urban extension of Gloucester City. If it is to be classed as an urban extension, then consideration must be taken into account regarding the 6 year land supply already available in Gloucester City. The Green Belt would consequently be at risk for no good reason.
· The site extends along the A417. The air quality at this site is in question and should be further investigated before it can be considered as a suitable site. Some modelling has been carried out, but the JCS recognises that more traffic modelling needs to be done to make sure large scale developments are viable. There has been no modelling at the C&G roundabout and no adequate assessment of the affects of major traffic along the A46 Shurdington Road ,where already high levels of noxious gases have already been recorded. Also the Air Balloon roundabout at Crickley Hill, notorious for constant air quality problems. The major increase in traffic will certainly exacerbate the problems.
The traffic noise along this stretch of land must also be scrutinised. NPPF states that planning policies must ‘avoid noise which will significantly impact on health and quality of life’ There is evidence that noise levels can be in excess of 70DB. This is without the further increase of traffic likely to occur as a result of the over development of Brockworth.
Both Brockworth Parish Council and Hucclecote Parish Council are against development of the Green Belt at Brockworth. Their reasoning is recorded in representations to TBC.