Cheltenham Plan (Part One): Preferred Options

Preferred Options

Responses

List of answers to the specified question
NameOptionTextDate
Brockhampton Land Consortium (- -)

1. Introduction 1.1 Brockhampton Lane Consortium (the Consortium) controls land within Cheltenham Borough at the proposed North West Cheltenham strategic allocation as defined in the emerging Joint Core Strategy (JCS). The JCS provides the strategic policy framework in which the Cheltenham Plan is formulated. 1.2 These representations focus on the consistency of the Cheltenham Plan’s, policies and proposals with the emerging JCS and national policy and guidance. 2. Consistency with the JCS 2.1 The JCS has reached the stage where consultation is being undertaken on Proposed Modifications following the Inspector’s Interim Report. Those Proposed Modifications identify a housing requirement for Cheltenham Borough of at least 10,917 dwellings from 2011-2031 (546 dwellings per year) and Policy SD2 plans for 10,997 dwellings. 2.2 The Proposed Modifications also identify that this will be provided within the Cheltenham Borough administrative boundary and cross-boundary urban extensions at North West Cheltenham (where the Consortium’s land lies) and West Cheltenham defined in Policy SA1, and commitments covered by any Memoranda of Agreement. Therefore the Consortium’s land is to be removed from the Green Belt through the JCS process. 2.3 In terms of completions and commitments for Cheltenham Borough, those total 3,779 dwellings of which completions comprise 1,426 dwellings. The urban extensions add a further 5,385 dwellings. Windfalls (865) and existing local plan allocation (10) and the Cheltenham Borough Local Plan (957)1 make up the rest of the supply total of 10,996 dwellings, though the Consortium notes that the Cheltenham Plan identifies a total supply of 10,989. 2.4 However, it is clear that there has been an under supply in the first five years of the plan period (1,426 against a requirement of 2,730) and the level of commitments is less than a five year supply requirement, even without the shortfall being taken into account. The Consortium notes that the JCS will be using the Liverpool method for managing Housing Supply because of the reliance on delivery from strategic sites, though it is noted that this element of supply is expected to start during 2017/2018 and there is little chance of this happening. 2.5 Given that the Proposed Modifications presents no policy to phase the housing requirement of Cheltenham, it is therefore important in terms of proper planning that the Local Plan seeks to maximise the potential of the strategic allocations, rather than, as in the case for the Consortium’s and at North west Cheltenham apply unnecessary constraints through the designation of Local Green Space. 1 All figures taken from JCS Table SP2a as proposed to be modified Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 3 For Brockhampton Lane Consortium 3. Local Green Space 3.1 The NPPF and NPPG set out the context for the designation of areas of Local Green Space. Paragraph 77 of the NPPF sets out the policy context for designating Local Green Space as follows: ‘The Local Green Space designation will not be appropriate for most green areas or open space. The designation should only be used: ● where the green space is in reasonably close proximity to the community it serves; ● where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and ● where the green area concerned is local in character and is not an extensive tract of land.’ 3.2 The Consortium strongly objects to the additional criteria inserted at the end of Paragraph 5.1.6 of the Cheltenham Plan which cannot be attributed to the NPPF. The Consortium also notes that Paragraph 76 of the Framework is only quoted in part with the reference to ‘…complement investment in sufficient homes, jobs and other essential services’ being omitted. 3.3 It is important to recognise that the NPPF is clear that Local Green Space will not be appropriate for most green areas or open space. The criteria are presented as a comprehensive test in that all need to be met in order for land to qualify. However, we deal with each of the criteria in turn. 3.4 The Consortium’s land is in close proximity to Swindon Village being located adjacent to existing development along it southern border. However, two points arise. Firstly the depth of land suggested for inclusion places its extremities over 300 metres distance from the edge of the settlement which the Consortium considers does not qualify as being in close proximity. Secondly, the criteria refers to being in close proximity ‘to the community it serves’. None of the Consortium’s land can be said to ‘serve’ the community as it is privately owned and in agricultural use. The exception to this is the bridleway along the northern brook and footpath along the eastern boundary, which are protected by other legislation2 and included as Green Infrastructure in the JCS. Therefore the Consortium believes that the land identified for Local Green Space fails this criterion. 3.5 In terms of being ‘demonstrably special’’ to the local community ‘and holds a particular local significance’, this test has not been met in that the only significance is that it 2 NPPG Paragraph: 018 Reference ID: 37-018-20140306 Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 4 For Brockhampton Lane Consortium is undeveloped at present. The Consortium’s land is not considered to have any characteristics of beauty to distinguish it from any other land in the locality. Similarly, there is no historic significance to the land (no Listed Buildings within or clearly viewed from the site and no archaeological constraints to development3 ). None of the Consortium’s land forms the setting to the Conservation Area as it is separated by intervening development. This is confirmed in the Swindon Village Conservation Area Character appraisal and management plan, February 2007. 3.6 The Consortium’s land has no recreational value, nor is it any more tranquil than any other undeveloped land surrounding a settlement falling within NEC B rather than NEC A4 . Similarly, there are no statutory designated ecological sites within or adjacent to the Consortium’s land with the nearest SSSI some 2.3km west of the land. There are also no non-statutory designated ecological sites within or adjoining the Consortium’s land. It is clear therefore that the proposed Local Green Space fails to meet the requirements of the second criterion of paragraph 77 of the NPPF. 3.7 The Consortium refers to Neighbourhood Plan Inspectors considering LGS on these criteria5 and would draw the parallels to the council’s attention: “On my site visit I did not see anything to indicate that this land was available for public recreational use. In addition I cannot identify any particular feature of this land that would distinguish it from the vast majority of other land surrounding the village nor can I see that it has any particular merit for special designation. I conclude, following a site visit, that this site does not meet the criteria for inclusion and should be deleted from the list in the policy.” “The site is in a countryside location on the outskirts of the settlement, projecting into the wider countryside. As such, the character of the site is as part of the surrounding countryside, rather than local in character. Whilst there is public access along the footpaths, and these footpaths appear to be well used by the local community, there are many areas of countryside where footpaths allow public access. It is not the purpose of the Local Green Space designations to include countryside land that provides wider views of the countryside. In my view, the site is a large area which projects into the open countryside and is part of the wider countryside rather than local in character. Thus, even with the historical significance and possible wildlife significance, I do not consider that this site meets the criteria for designation as Local Green Space.” 3 Oxford Archaeology September 2007 4 ANV Noise and Vibration Assessment February 2008 5 Rolleston-on Dove NP Examiner, Christopher Collison held of a site known as College Playing Fields; Chapelen-le-Frith NP, Examiner Janet Cheesley held of a site known as Target Wall Field Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 5 For Brockhampton Lane Consortium 3.8 The proposed Local Green Space covers some 24 hectares. Whilst the NPPG is clear that there is no hard and fast rule on how big a Local Green space can be it is also clear that ‘...blanket designation of open countryside adjacent to settlements will not be appropriate. In particular, designation should not be proposed as a ‘back door’ way to try to achieve what would amount to a new area of Green Belt by another name’ 6 . 3.9 Once more NP Examining Inspectors7 have made judgements in terms of extensive as follows: In the case of Farleigh Fields, it is my view that 19 hectares also comprises an extensive tract of land. To provide some perspective, at least twenty three full size football pitches would easily fit in to an area of this size. In the case of Farleigh Fields, it is my view that 19 hectares also comprises an extensive tract of land. To provide some perspective, at least twenty three full size football pitches would easily fit in to an area of this size. Given that the Framework is not ambiguous in stating that a Local Green Space designation is not appropriate for most green areas or open space, it is entirely reasonable to expect compelling evidence to demonstrate that any such allocation meets national policy requirements. Specific to demonstrating that Farleigh Fields, and Moor Lane Fields are not extensive tracts of land, no substantive or compelling evidence has been presented.” 3.10 Inspectors for NPs at Arlewas, Sedlescomeb, Tattenhil and Oakley and Deane came to similar conclusions in relation to parcels of 2.5 and 3.9has; 4.6has; 9.2 and 4.3has; and just over 5has. The Consortium therefore considers that the proposed Local Green Space is an extensive tract of land and fails to comply with the third criterion on paragraph 77 of the NPPF. Nor does it meet the selection criteria at Appendix B to the Cheltenham Plan in this respect. 3.11 It has clearly been demonstrated that the proposed Local Green Space fails to satisfy any of the criteria of paragraph 77 of the NPPF and cannot therefore be considered suitable for designation as Local Green Space. 3.12 The NPPG is clear that ‘Designating any Local Green Space will need to be consistent with local planning for sustainable development in the area. In particular, plans must identify sufficient land in suitable locations to meet identified development needs and the Local Green Space designation should not be used in a way that undermines this 6 NPPG Paragraph: 015 Reference ID: 37-015-20140306 7 Backwell NP Examiner Nigel McGurk held in relation to a site known as Farleigh Fields and Moor Lane Fields; Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 6 For Brockhampton Lane Consortium aim of plan making’ (our emphasis)8 . Given the identified issues in relation to the lack of deliverable housing supply identified at Section 2 above including the optimistic and housing trajectories relied upon for the proposed JCS allocations around Cheltenham, the identified Local Green Space at Swindon village is clearly contrary to the NPPG in this regard as it could contribute additional dwellings as part of the Strategic Allocation which is proposed to be removed from the Green Belt. 3.13 The Consortium notes that Paragraph 5.3.4 attributes the JCS as providing the indicative plan where LGS should be designated. However, the Consortium considers that it is clearly not the role of the JCS, as a strategic planning document, to make that judgement. 3.14 In addition, the Consortium’s land is one of the few significant opportunities to meet the housing needs of Cheltenham that lie within the Borough and is not significantly constrained with the exception of its current location in the Green Belt. It relates well to the Town, and the Consortium considers that there is significant justification to maintain the allocation to meet the housing needs of Cheltenham rather than designate the area Local Green Space. 3.15 For these reasons the Consortium strongly objects to the designation of its land within proposed Policy GE8A m) and the proposals map.

22 Mar 2017 13:23
Demoguide Limited (- -)

REPRESENTATIONS TO THE CHELTENHAM PLAN (PART ONE): PREFERRED OPTIONS

These representations are made on behalf of our client, Demoguide Limited, in relation to the Cheltenham Plan (Part One): Preferred Options, which is undergoing consultation until Monday 20th March 2017.

The representations relates to the former Premier Products site that is identified at paragraph 6.5.8 of the preferred options document as having the potential to support around 70 dwellings.  We’d like to support this potential allocation as part of the emerging Cheltenham Plan and have set out below some of the key planning considerations that should be taken into account as the plan progresses.

Site Location

 

The property is situated in the predominantly residential area of Prestbury, approximately 2 miles north east of Cheltenham town centre. Other uses in the immediate area comprise a primary school, small retail parade and food store. A cemetery is located to the rear of the property.

 

Key Planning Considerations

 

National Planning Policy Framework (NPPF)

National planning policy is set out in the National Planning Policy Framework (NPPF) (March 2012). Relevant policies are as follows:

  • A presumption in favour of sustainable development, including granting permission where the development plan is absent, silent or relevant policies are out-of-date unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, or specific policies in the Framework indicate development should be restricted (para. 14).
  • Avoiding the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses should be treated on their merits having regard to market signals (para. 22);
  • To boost significantly the supply of housing, including the identification of a five year deliverable supply plus an additional buffer of 5% or 20% (para. 47); and
  • Housing applications should be considered in the context of the presumption in favour of sustainable development and relevant policies for the supply of housing should not be considered up-to-date if the LPA cannot demonstrate a five year supply of deliverable housing sites (para. 49).

Cheltenham’s Housing Land Supply

 

Cheltenham’s most up-to-date position on its deliverable housing land supply is set out in its Authority Monitoring Report (December 2015). This indicates a supply of 3.9 or 3.6 years (5%/20% buffer) which equates to a shortfall of 669 - 1,010 dwellings to 2020. As such, it is clear that the Authority cannot demonstrate a five year deliverable supply, meaning that any residential planning applications must be considered in the context of the presumption in favour of sustainable development.

Cheltenham Borough Council’s Housing Monitoring report reveals that the Council cannot currently show a 5 years supply of housing and that this is around 3 years.  This is a very significant shortfall and will need to weigh very heavily in favour of this site being redeveloped for residential purposes. 

 

Key Planning Considerations  

 

This site in question has been marketed since the end of 2014.  As part of the marketing strategy a website was set up to deal solely with advertising the site as well as placing adverts in key property documents to publicise its availability. This has not generated any further interest for its re-use for employment purposes.   This is recognised by the Council, who have considered that due to the lack of interest in the site for on-going employment use that a residential redevelopment would be the most appropriate, and the site is allocated for such purposes in the emerging plan.   

In line with the guidance in the NPPF, alternative uses proposed should be treated on their merits.  The proposed residential allocation will result in a sustainable form of development. Further to this, the NPPF at paragraph 51 also states that changes of use of sites currently in ‘B’ use classes should be considered where there is an identified housing need. In this case, Cheltenham Borough currently has a shortage of housing and shows a deficit of approaching two years in its five year housing land supply.

 

Deliverability of the site

 

The National Planning Policy Framework states that for sites to be considered ‘deliverable’ means they will be available now, in a suitable location now and achievable within five years and viable, as per footnote 11 of paragraph 47.

Available

 

The site is un-used and in single ownership. Apart from the former employment use of the site there are no physical constraints that would prevent or delay development coming forward. It can, therefore, be considered to be available now.

 

Suitable

 

The site is suitably and sustainably located for residential development with good accessibility to local services, facilities and employment opportunities via foot and other sustainable modes of transport.

Achievable

Residential development represents a viable future use for the site which can be delivered quickly.

Conclusion

 

We would like to support the emerging allocation of the site in question for residential development. 

The above assessment demonstrates that the former Premier Products site is available now and in a suitable location for residential development. Similarly, it would be viable for residential redevelopment to be delivered at the site and there are no constraints that would prohibit the site from coming forward.

---------------------------------------------------------------------------------------

REPRESENTATIONS TO THE CHELTENHAM PLAN (PART ONE): PREFERRED OPTIONS

These representations are made on behalf of our client, Demoguide Limited, in relation to the Cheltenham Plan (Part One): Preferred Options, which is undergoing consultation until Monday 20th March 2017.  This letter is to specifically promote the reuse/redevelopment of Lansdown Industrial Estate for mixed use development comprising residential and employment.  

Summary of the Proposals

 

The site has a total area of 5.41ha and it is suggested that the site is redeveloped to comprise a mixed use development that includes a range of existing and proposed employment opportunities, residential and associated open space. 

Suitability of the site for employment redevelopment in its entirety

 

As matters stand, this site is protected under existing policy EM2 of the current Cheltenham Plan and will continue to be in the emerging plan.  However, it is considered that this site should be included within the plan for mixed use development and the reasons for doing so are set out below.    

In simple terms, it is not possible to retain/redevelop the site for employment purposes in its entirety because it is just not a viable proposition.  The only way the estate can be taken forward practically at this stage is if the site is advanced as a mixed use redevelopment that comprises part residential and part employment.  The capital returns associated with the residential units can be used to invest in the employment element of the site that will be retained.  Moreover, due to the poor nature of a large proportion of the buildings that occupy the site that are no longer fit for purpose, providing a mixed use scheme is the only credible way to take this site forward. 

Further to the above, it is recognised, due to the location of the site and its existing access, which can’t be changed, that the estate presents itself poorly in terms of general viability and the access is far from ideal for servicing the estate.  

Vacancy Rates

 

Many of the leases are due to expire in 2018 which coincides with the fact that many of the buildings will need upgrading at that stage as it will be illegal for them to be let due to their Energy Performance Certificate (EPC) rating.  From April 2018, it will be unlawful to lease commercial property which has less than an E (125) Energy Performance Rating. Currently around 24% of buildings on the estate have an EPC of F or below and as 92% of the leases expire in 2018 investment will need to be undertaken at that stage otherwise the buildings will become obsolete.  In this respect, the need for investment through redevelopment is clearly pressing.

EPC Ratings and Condition of Buildings

As matters stand, significant work is required to bring the EPC rating of the buildings down.  In essence, the combination of the poor state of repair and EPC ratings mean that many of the buildings are coming to the end of their life cycle and, as discussed, it is going to become increasing difficult to let a significant proportion of the units legally from 2018.  Moreover, given that the majority of tenancies are coming to a natural end their renewal will not be possible due to the state of the buildings and this therefore provides the opportunity look at the refurbishments and redevelopment proposed. 

Displacement of Existing Businesses

 

Tenants are choosing to leave Lansdown as it no longer provides the accommodation required or being sought, and requires modernisation and considerable improvement.  All of which is not possible without the redevelopment proposed, and any new potential occupier will look elsewhere due to traffic, access, poor accommodation, non-compliance with future legislation beyond 2018 and the fact there are more modern premises available in Gloucester.  In this respect, the displacement of tenants is occurring already and will continue without the redevelopment proposed.  Moreover, as already highlighted, existing tenancies run out at the end of 2018 and, as a result, tenants will naturally be displaced anyway with or without redevelopment. 

Deliverability of the site

 

The National Planning Policy Framework states that for sites to be considered ‘deliverable’ means they will be available now, in a suitable location now and achievable within five years and viable, as per footnote 11 of paragraph 47.

Available

 

The site is un-used and in single ownership. Apart from the employment use of the site there are no physical constraints that would prevent or delay development coming forward. It can, therefore, be considered to be available now.

 

Suitable

 

The site is suitably and sustainably located for mixed use development with good accessibility to local services, facilities and employment opportunities via foot and other sustainable modes of transport.

Achievable

Mixed-use development represents a viable future use for the site which can be delivered quickly.

Conclusion

 

Given the above, it is considered that the Lansdown Industrial Estate can’t be realistically retained for employment land in perpetuity and should be considered for a mixed use redevelopment as part of the Cheltenham Plan Review. 

I trust that the above and enclosed information is of assistance at this stage. However if you require any further information or have any queries please don’t hesitate to contact me.

Yours sincerely,

Giles Brockbank MRTPI

Hunter Page Planning

20 Mar 2017 17:21
Newbridge Construction Limited…

REPRESENTATIONS TO THE CHELTENHAM PLAN (PART ONE): PREFERRED OPTIONS These representations are made on behalf of our client, Newbridge Construction Limited, in relation to the Cheltenham Plan (Part One): Preferred Options, which is undergoing consultation until Monday 20th March 2017. Newbridge Construction Limited is the long-standing owner of land at Brizen Farm, south-east Cheltenham, and representations have previously been submitted promoting the site to the Joint Core Strategy and Tewkesbury Borough Plan. Submissions have been made to the Draft Joint Core Strategy (JCS), Pre-Submission JCS, JCS Examination; and also to Tewkesbury Borough Council’s Assessment of Land Availability ‘Call for Sites’, and Tewkesbury Borough Plan: Draft Policies and Site Options. Whilst situated in the Green Belt, the Land at Brizen Farm lies immediately adjacent to the existing urban area of Cheltenham and would, therefore, allow for a logical and appropriate addition to the Town. A site location plan is enclosed. It is acknowledged that Brizen Farm is located outside Cheltenham Borough Council’s administrative boundary (and falls within Tewkesbury Borough); however the site would contribute towards Cheltenham Borough Council’s housing needs due to its location on the edge of Cheltenham, and therefore our client wishes to highlight its suitability to deliver housing. The Site Location The site is located south of the Shurdington Road (A46) on the south-eastern edge of Cheltenham, within the administrative area of Tewkesbury Borough Council. It is highly accessible with a range of services and facilities accessible via foot, bicycle or public transport. There is a good standard of footway provision and there is potential for upgrading existing walking routes to provide both walking and cycling provision. Also, there are existing crossing points located along the length of the Shurdington Road. The road network surrounding the site is accessible for bicycles and connects to cycle routes around Cheltenham. In addition, the site is well served by public transport with existing stops for bus services 10 and 61 located on the 2 Shurdington Road opposite and within walking distance of the site. Both bus stops provide convenient and frequent access by bus to a range of local destinations including Cheltenham Town Centre. Description The site is approximately 28.84 hectares of agricultural land. As above, it is located immediately adjacent to the A46, which forms its north-western boundary, and is a main route connecting Cheltenham to the South, including Gloucester and the M5 motorway. The land is relatively flat and is largely contained by mature hedgerows to the south and west and existing residential areas to the north-east, north-west and partially to the south-east which are on higher ground. These built and natural features restrict views in and out of the site. Planning History The land is ideally located for residential development. Outline planning application (LPA reference 13/00415/OUT) for 175 units on 10.19 hectares demonstrated that there are no physical constraints preventing residential development at the site. The application was accompanied by an Environmental Statement and a full raft of technical reports which provided the necessary evidence to support this conclusion; copies of these documents can be provided if necessary. Furthermore, whilst the application was refused this was solely on the basis of the site’s location within the Cheltenham/Gloucester Green Belt. Accordingly, if the site were to be removed from the Green Belt it could be delivered without delay. Designations The site is wholly located within the Green Belt and Brizen Farmhouse is Grade II listed. The impact on heritage assets was assessed as part of the above planning application, and the illustrative masterplan sought to mitigate the impact of development upon the setting of Brizen Farmhouse. The site is not affected by any other landscape or environmental designation but the Cotswold Area of Outstanding Natural Beauty (AONB) lies to the south-east of the site. Key Considerations Green Belt Document EXAM 196 of the JCS Examination is the ‘Green Belt, Safeguarded Land and Spatial Strategy Update Paper’ which aims to answer the Inspector’s further questions on Green Belt matters asked during the January 2016 hearing sessions. In regards to alternative sites, Appendix B of EXAM 196 sets out the planning status of Tewkesbury Borough’s alternative Green Belt Sites. In relation to Brizen Farm, it states that there was a proposal for a previous application for 175 dwellings and there has been no further masterplan submitted as part of the submission to the pre-submission JCS. However, the planning application assessed all technical matters in detail through the production of an Environmental Statement and prepared an illustrative masterplan which was landscapeled and sensitively designed. EXAM 196 also states the following: ”Evidence from the 2016 SALA’s shows that the JCS authorities do not need to rely on further Green Belt changes in district plans to meet objectively assessed need. There is however a desire to maintain the option of small releases at both Cheltenham and Tewkesbury, where exceptional circumstances can be demonstrated. Any smaller, local Green Belt revisions are properly addressed through these District Plans in accordance with the proposed revised SD6 policy supported by appropriate local evidence. These revisions to 3 the Green Belt would need to demonstrate exceptional circumstances through the examination of those plans” (Our underlining). Furthermore, the JCS Inspector’s Interim Report (May 2016) (examination doc ref. EXAM 232) states the following at paragraph 150: “The removal of Leckhampton as a strategic allocation and the reduction of housing numbers at North West Cheltenham leaves Cheltenham with a need to find alternative housing capacity. The newly proposed strategic allocation of West Cheltenham will go part way to doing this, although a deficit still remains. In my judgement there is additional potential capacity in non-strategic Green Belt sites, which could significantly increase Cheltenham’s district capacity and which could be allocated in the emerging Cheltenham Local Plan.” Further information on the reduction of housing numbers at Leckhampton is provided below. However, the Inspector has made it clear that non-strategic Green Belt sites are needed to meet Cheltenham Borough Council’s housing deficit. Leckhampton Allocations In the JCS Inspector’s Preliminary Findings on Green Belt Release Spatial Strategy and Strategic Allocations (EXAM 146), concern was raised regarding the landscape sensitivity of the Leckhampton allocation, particularly the Tewkesbury part of the allocation (land south west of Farm Lane). The reason for this is that the ‘Landscape Report’ (Landscape and Visual Sensitivity and Urban Design Report) highlights that this part of the site falls within the highest category of landscape and visual sensitivity, given its proximity to the AONB. Moreover, EXAM 232 recommends a significant reduction in the Leckhampton allocation. The Inspector states the following at paragraphs 123 and 124: “Overall, in my judgement, a limited amount of development could be supported towards the north of the site where public transport is more accessible, subject to the avoidance of land of high landscape and visual sensitivity. Therefore, for reasons of landscape/visual amenity and highway impacts, I recommend that the Cheltenham part of the site be allocated for a modest level of built development in the order of 200 dwellings. “This remaining modest level of housing would not classify as an urban extension and, therefore, it would be more appropriate to allocate the site in the emerging Cheltenham Local Plan rather than in the JCS. It is, therefore, my recommendation that the Leckhampton urban extension be removed in its entirety from the JCS.” In comparison to the Leckhampton site referred to, Brizen Farm falls within ‘medium’ landscape sensitivity, which is the same category as the Cheltenham land that the Inspector is minded to find sound. This land is included within the Cheltenham Borough Plan for 200 homes. The landscape sensitivity of Brizen Farm was considered as part of the previous application on site, with the committee report stating that the “the Landscape Officer considers that the LVIA demonstrates that the overall impact of development would be moderate given the proposed design, layout and mitigation measures. Furthermore, the surrounding sensitive landscape character could accommodate the development if the principle of development was found to be acceptable”. It is therefore clear, as identified in the evidence base that the Inspector refers to, that Brizen Farm is less sensitive in the landscape than the Farm Lane part of the Leckhampton allocation which the JCS Inspector has found to be unsound. Based on the conclusions of the Inspector, the Cheltenham Plan preferred Options document looks to allocate the Cheltenham parcel of the original Leckhampton allocation for 200 dwellings. The scale of development recommended by the Inspector would not classify as an urban extension and therefore the 4 recommendation was to allocate through the Borough Plan instead. Brizen Farm could provide additional housing at this location, at a similar scale. Deliverability of the site The National Planning Policy Framework states that for sites to be considered ‘deliverable’ means they will be available now, in a suitable location now and achievable within five years and viable, as per footnote 11 of paragraph 47. Available The site is un-used and in single ownership. The previous planning applications referenced confirm that there are no physical constraints that would prevent or delay development coming forward. It can, therefore, be considered to be available now. Suitable The site is suitably and sustainably located for residential development with good accessibility to local services, facilities and employment opportunities via foot and other sustainable modes of transport. This is acknowledged in Tewkesbury Borough Council’s 2011 and 2012 SHLAAs and the 2012/13 SALA. Accordingly, the site is clearly a suitable location for residential development. Achievable Residential development represents a viable future use for the site which can be delivered quickly; this has been demonstrated by the previous planning application relating to the site. It is evident that the only constraint of the site is its Green Belt designation. Therefore, if it were removed from the Green Belt the site could deliver housing immediately. Conclusion The above assessment demonstrates that land at Brizen Farm, Shurdington Road is available now and in a suitable location for residential development. Similarly, it would be viable for residential development to be delivered at the site, and this has been demonstrated by previous planning applications. The site is clearly constrained by its Green Belt designation and this is the only barrier to development coming forward. Although located in Tewkesbury Borough, the site would serve Cheltenham and is ideally situated to help meet Cheltenham Borough Council’s housing need. The JCS Inspector has made it clear that non-strategic Green Belt sites are needed to help meet the housing need of Cheltenham Borough and it is requested that due consideration is given to Brizen Farm as being able to meet this need in a suitable and sustainable location. Hunter Page Planning has extensive knowledge about this site including the vast amount of technical reports that substantiate the above conclusions. Please do not hesitate to contact me should you require any further information.

20 Mar 2017 17:10
Deleted User

1 INTRODUCTION 1.1 Context 1.1.1 These representations are submitted by Gladman Developments Ltd. (from here on referred to as Gladman) in response to the current consultation on the Cheltenham Plan (Part One) Preferred Options consultation. Gladman welcome the opportunity to respond to this consultations and request to be kept informed of further progress with the Local Plan. 1.1.2 Gladman Developments Ltd (from here on referred to as Gladman) specialise in the promotion of strategic land for residential development with associated community infrastructure. Gladman have been involved in a significant number of Local Plans across the country, both through the Plan preparation stages (through written representations) and through participation at the Examination in Public (EiP) stage. Through this experience Gladman have become acutely aware of the need for Local Plans to meet the tests of soundness and be based on robust up to date evidence. 1.2 Gloucester Cheltenham and Tewkesbury JCS 1.2.1 The Joint Core Strategy (JCS) is a partnership between Gloucester City Council, Cheltenham Borough Council and Tewkesbury Borough Council. The JCS was formed to produce a coordinated strategic development plan for the period up to 2031. 1.2.2 The JCS was submitted for examination in November 2014 and the examination remains ongoing. The list below identifies some of the key stages of the Examination process to date. • May 2015: Hearing sessions commenced • July 2015: Viability Round Table Session • July 2015: SHMA Round Table Session • September 2015: Deadline for JCS authorities to provide initial responses to Inspector’s Stage 1 requests • January 2016: Hearings re-opened • March 2016: Stage 3 hearings commenced • May 2016: Inspector’s interim report received • July 2016: Interim Report hearings commenced • February to April 2017: Proposed Main Modifications consultation. Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. 1.2.3 Gladman have been actively involved throughout the JCS preparation and examination, having submitted written representations at various consultation stages and appointed specialist consultants to prepare and present evidence in relation to objectively assessed housing need during the examination stage. 1.2.4 The Gloucester Cheltenham and Tewkesbury JCS will contain the overarching strategic level policies and strategic sites, whereas the Cheltenham Plan (along with the Tewkesbury Borough and Gloucester city Local Plans) will provide a more local level of detail. 1.2.5 The Cheltenham Plan is coming forward in two parts. The Part One document will deal primarily with policies relating to the development and protection of land for residential and employment use, the designation of Local Green Space and the Economic strategy. Part Two of the Plan, which is intended to be published for consultation later this year, will contain the more detailed development management policies on various topics. 1.3 National Policy 1.3.1 The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard we submit that in order to prepare a sound plan it is fundamental that it is: • Positively Prepared – The Plan should be prepared 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 a proportionate evidence base. • 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. 1.4 Housing White Paper – ‘Fixing our Broken Housing Market’ 1.4.1 The Government White Paper (‘Fixing our Broken Housing Market’) issued in February 2017 is a very clear statement from Government on the importance of the delivery of housing to the wider economy and the foreword by the Secretary of State, Sajid Javid, confirms that significant change in the pace of housing delivery is required to have any effect on the housing crisis we face: Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. “For decades the pace of house building has been sluggish at best. As a result, the number of new homes has not kept pace with our growing population. And that, in turn, has created a market that fails to work for far too many people. Soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation… …That has to change. We need radical, lasting reforms that will get more homes built right now and for many years to come.” 1.4.2 The White Paper makes it abundantly clear that a key focus and objective for the Government is the delivery of much needed housing and consequently Local Plans should reflect this in their housing requirements, overall strategy and development management policies. Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. 2 VISION AND OBJECTIVES 2.1 Vision Theme A 2.1.1 In principle, Gladman supports the Council’s vision and objectives. In particular, we support Objective b) of Theme A which seeks to ensure provisions of sufficient housing land and other opportunities for residential development that meets the needs of the current and future population of the Borough. 2.1.2 However, it is suggested that more work may need to be done through the preparation of this plan to ensure that this objective can be realised, in particular sufficient provision of housing land through allocations and amendments to the PUA to ensure the plan is effective and justified. Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. 3 LOCAL GREEN SPACE 3.1 Context 3.1.1 Gladman suggest it is not clear why the decision has been made to review saved Green Space policies as part of the Cheltenham Plan Part 2 and why the work is not done alongside the Local Green Spaces policy. It is considered unhelpful for a user of the plan and Gladman suggests that policies regarding the use of Green Space should be contained within the same Local Plan document. As such, Gladman suggests that the Local Green Space policy is removed from the Cheltenham Local Plan Part 1 and included in the Local Plan Part 2 when sufficient evidence has been produced to determine the protection necessary for each green space. 3.2 Background 3.2.1 This policy is seeking to designate parcels of land as Local Green Space (LGS). Gladman takes this opportunity to remind the Council of paragraphs 76 through to 78 of the Framework, which sets out the process for designating LGS. As paragraph 77 states: ‘The Local Green Space designation will not be appropriate for most green areas or open space. The designation should only be used: • Where the green space is in reasonably close proximity to the community it serves; • Where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and • Where the green area is local in character and is not an extensive tract of land.’ 3.2.2 The Planning Practice Guidance (PPG) provides further guidance on LGS designations including paragraph ID. 37-015-20140306, “There are no hard and fast rules about how big a Local Green Space can be because places are different and a degree of judgement will inevitably be needed. However, paragraph 77 of the National Planning Policy Framework is clear that Local Green Space Designation should only be used where the green area concerned is not an extensive tract of land. Consequently, blanket designation of open countryside adjacent to settlements will not be appropriate. In particular, designation should not be proposed as a ‘back door’ way to try to achieve what would amount to a new are of Green Belt by another name.” 3.2.3 Only parcels which meet all of the tests from paragraph 77 of the Framework should be designated as LGS. 3.2.4 The two options presented within the plan are whether to include LGS that is already protected by saved policies GE1 and GE2 or to not include them due to them already being protected. These saved policies will be reviewed as part of the Local Plan Part 2 and as the outcome of this review Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. will not be known for some time this should not be a consideration moving forward. Indeed, Gladman submit that these policies are not Framework compliant and should not be used or relied upon. 3.2.5 In accordance with the Framework a Local Green Spaces policy should offer stronger protection, equivalent to that similar of the Green Belt, than other green space policies. This is not currently the case and the saved policies of GE1 and GE2, as written, provide a stronger protection than the emerging LGS policy. Until these policies are reviewed to accord with the Framework to indicate what protection would be appropriate Gladman contend that a LGS policy should not be brought forward. 3.3 Policy GE8A and Policy GE8 3.3.1 Gladman contends that land at Swindon Village, measuring 47 hectares, is an extensive tract of land. Further, this has been allocated for housing as part of the JCS and as a masterplan for this allocation has not been finalised it could be seen to prejudice the ability of the allocation to deliver the number of homes targeted. Allocating LGS to act as a green buffer would not accord with the purposes of LGS, a green buffer would be an entirely different policy designation. As such this LGS designation should be removed from both policy GE8A and GE8. 3.3.2 This area is being removed from the Green Belt through the JCS yet this policy would still provide the same level of protection as the Green Belt and in effect return the site to the Green Belt by the ‘back door’. Further, LGS should only be designated where it can last well beyond the plan period in which it is designated. This cannot be guaranteed without prejudicing the potential of the strategic allocation in the JCS to come forward. 3.3.3 If it is considered necessary that this parcel of land should provide a green buffer between Swindon Village and the strategic allocation then this would need entirely different evidence to support inclusion of what would be an area of separation policy, it should not be designated as LGS for this purpose. 3.3.4 Further, as land at Pilgrove has been found not to meet all the tests for LGS designation this should also not be included within the policy. 3.3.5 Inclusion of these two sites within the policy will likely be found unsound at examination as the policy could not be justified and would not be consistent with national policy, in regards to Local Green Space designation. Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. 4 DEVELOPMENT PROPOSALS 4.1 Housing Need 4.1.1 The housing need figure outlined for Cheltenham as set out in the JCS is for at least 10,996 new homes; this has increased from 10,665 during examination of the Plan and its evidence base. 4.1.2 Gladman has been involved in the OAN debate during the examination process and feels this figure is still short of the full OAN. Gladman commissioned Barton Willmore to undertake a review of the OAN, who suggest a figure of 12,142 would be more appropriate for Cheltenham and a closer reflection of the full OAN. 4.1.3 Further, the 10,665 figure should be considered a minimum as the policy states ‘at least’. If it was to be a maximum it would be setting a cap to development which would directly conflict with the objectives of the Framework to significantly boost the supply of housing. 4.1.4 Through the Cheltenham Local Plan Part 1 allocations have been identified additionally to the strategic allocations in the JCS. A total housing supply of 10,989 has been identified for the plan period, a figure below the requirements set out in the JCS main modifications. Gladman suggests further allocations will be necessary to meet the objectives of the plan, providing flexibility and maintaining a healthy land supply. Gladman recommend identifying a buffer of 20% of sites to provide sufficient flexibility so as not to over rely on strategic allocations of the JCS. This would ensure the necessary scale of housing provision can still be delivered in circumstances where any of the proposed allocations do not come forward as envisaged. 4.2 Housing Allocations 4.2.1 One of the aims of the Cheltenham Plan is to ensure that the Council maintains a healthy supply of land for housing. Gladman notes that the Cheltenham Plan will be heavily reliant on the delivery of large strategic allocations to achieve this. 4.2.2 To achieve the aims of the Cheltenham Plan, the Council should be mindful that to maximise housing supply the widest possible range of sites, by size and market location, are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products. The key to increased housing supply is the number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increases housing delivery. 4.2.3 Without further site allocations or policies allowing additional windfall development to come forward the plan should be found unsound at examination as it is not considered to be positively prepared nor will it be effective. Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. 5 PRINCIPAL URBAN AREA 5.1 Amendments to the PUA 5.1.1 Gladman would be opposed to the use of settlement limits to arbitrarily contain the physical growth of Cheltenham town. The use of defined settlement limits does not accord with the positive approach required by the Framework, which makes clear that development which is considered to be sustainable should not be delayed, in accordance with the presumption in favour of sustainable development. Instead, development proposals should be considered on a case by case basis and the following wording is submitted to the Council for consideration: “When considering development proposals, the Council will take a positive approach to new development that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. Applications that accord with the policies of the Local Plan will be supported particularly where they provide: - New homes including market and affordable housing; or - Opportunities for new business facilities through new or expanded premises; or - Infrastructure to ensure the continued vitality and viability of a settlement. Development adjacent to Cheltenham town will be permitted provided that any adverse impacts do not significantly and demonstrably outweigh the benefits of development.” Cheltenham Plan (Part One) – Preferred Options Consultation 2017 Gladman Developments Ltd. 6 CONCLUSIONS 6.1 Key conclusions 6.1.1 In order to meet the tests of soundness contained at paragraph 182 of the Framework, the emerging Local Plan Part 1 must be found to be positively prepared, effective, justified and consistent with national policy. 6.1.2 Having reviewed the Cheltenham Plan Part 1 Preferred Options Gladman are concerned that the plan is not consistent with national policy in regards to the designation of Local Green Spaces and that by progressing the plan before the fully known housing needs for Cheltenham have been established, through the Joint Core Strategy, the plan cannot be seen to be positively prepared, effective or justified. Amending and not removing the tightly drawn Principal Urban Area boundary is considered to be restrictive and not positively preparing the plan. 6.1.3 We trust that these comments have been constructive and would welcome the opportunity to discuss any of the issues raised with the Council.

20 Mar 2017 16:05
Deleted User

CHELTENHAM PLAN (PART ONE) 2011 TO 2031 PREFERRED OPTIONS CONSULTATION MARCH 2017 REPRESENTATIONS ON BEHALF OF STRATEGIC LAND PARTNERSHIPS Cheltenham Plan (part one) 2011 to 2031 Preferred Options Consultation March 2017 1. Introduction 1.1 Strategic Land Partnerships (SLP) controls land within Cheltenham Borough at Glenfall Way (See site Plan at Appendix 1). The site lies within the Cotswold AONB and is immediately adjoining the defined Urban Area as set out in the adopted Local Plan that covered the period to 2011. 1.2 These representations focus on the consistency of the Cheltenham Plan’s policies and proposals with the emerging JCS and national policy and guidance. 2. Consistency with and impact on the JCS 2.1 SLP notes that the emerging Joint Core Strategy (JCS) sets the strategic framework within which the Cheltenham Plan is formulated. 2.2 The JCS has reached the stage where consultation is being undertaken on Proposed Modifications following the Inspector’s Interim Report. Those Proposed Modifications identify a housing requirement for Cheltenham Borough of at least 10,917 dwellings from 2011-2031 (546 dwellings per year) and Policy SD2 plans for 10,997 dwellings. 2.3 The Proposed Modifications also identify that this will be provided within the Cheltenham Borough administrative boundary and cross-boundary urban extensions at North West Cheltenham and West Cheltenham (both of which are partly within Tewkesbury Borough) and commitments covered by any Memoranda of Agreement. 2.4 In terms of completions and commitments for Cheltenham Borough, those total 3,779 dwellings of which completions comprise 1,426 dwellings. The urban extensions add a further 5,385 dwellings. Windfalls (865) and existing local plan allocation (10) and the Cheltenham Plan (957)1 make up the rest of the supply total of 10,996 dwellings, though SLP notes that the Cheltenham Plan identifies a total supply of 10,989. 2.5 From the figures above, it is clear that there has been an under supply in the first five years of the plan period (1,426 against a requirement of 2,730) and the level of commitments is less than a five year supply requirement, even without the shortfall being taken into account. SLP notes that the JCS will be using the Liverpool method for managing Housing Supply because of the reliance on delivery from strategic sites. It is noted that this element of supply is expected to deliver from 2017, however, given that detailed planning permissions are not in place SLP believes that there is little chance of this happening. 2.6 Given that the Proposed Modifications has no policy to apply a phased approach to the housing requirement for Cheltenham, it is important in terms of proper planning that the Local Plan identifies sufficient sites that have the potential to boost supply in the short term. 1 All figures taken from JCS Table SP2a as proposed to be modified Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 2.7 In terms of the site allocated in the Cheltenham Plan, SLP notes that only four of those sites, with a capacity of 244 dwellings are projected to be available in the first five years of the Plan. Two of these are previously developed and whilst it is noted that they are recorded as being vacant, experience in Cheltenham of relying on such sites to deliver according to timescales would suggest a more cautious approach. 2.8 Of the five mixed use sites allocated in the Plan, four are brownfield and a number have been previously allocated, without coming forward, or subject to un-implementable planning schemes. Whilst it is noted that the sites do not contribute in the first five years, the 200 plus dwellings that these sites contribute to the identified Housing Supply cannot be relied upon. 2.10 From the above, it is clear that additional capacity should be accommodated within the Cheltenham Plan in order to meet the housing requirement that the JCS relies upon. In order to achieve this, SLP believes that further sites such as that at Glenfall Way should be included in the Principal Urban Area boundary. The following paragraphs set out the reasoning for this site to be so included. 3. Review of land in AONB and justification for allocating site at Glenfall Way 3.1 As set out above, the Cheltenham Plan as an important role to play in delivering the housing requirements for the Joint Core Strategy. There is also a clear need to boost Housing Supply at Cheltenham in the short term and the allocations identified in the Cheltenham Plan, even if developed as set out in the plan, will not increase the supply by more than half a year. 3.2 The site at Glenfall Way is located adjoining the identified Principal Urban Area as defined by the Cheltenham Plan. Whilst it is within the AONB, it is on the edge of that designation. 3.3 SLP notes that the evidence base to the Cheltenham Plan includes an assessment of land within the AONB on the urban fringe prepared by Ryder Landscape Consultants 2 . That study identifies just four areas adjoining the urban area where the AONB landscape has capacity to accommodate development. One of those is included as part of a mixed use allocation in the Cheltenham Plan at Prior’s Farm Fields. Another comprises the northern 0.7ha part of SLP’s site at Glenfall Way (see Appendix 2). 3.4 Given the low number of instances where development would be suitable and the need to boost housing supply in the short term, SLP considers that the area identified at Glenfall Way should be included within the Principal Urban Area boundary. 2 Landscape Character, Sensitivity and Capacity Assessment of Cotswold AONB Within the Cheltenham Borough Administrative Area, April 2015 Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 3.5 Due to its urban fringe location, the site does not form a significant part of the wider rural countryside. The site is situated within already developed areas of settlement, and is not isolated from the existing residential areas of Cheltenham. It is considered that residential development on this site would have a limited low risk of encroachment into the countryside. 3.6 There are no constraints other than the AONB. It is sustainably located with good access to employment and services and good public transport links. 3.7 The site offers the ability to open up new public pedestrian rights of way from Glenfall Way to the Cheltenham Circular Walk to the south east of the site avoiding the route of waste vehicles, thereby improving permeability and accessibility for the wider area. There are no historic features, statutory or non-statutory, of acknowledged importance located at or in close proximity to the site. 3.8 The site falls within Flood Zone 1 as identified within the Environment Agency’s latest mapping data. A Flood Risk Assessment and Drainage Strategy have been produced for the site. That work demonstrates development at the site is not at flood risk, it also demonstrates sufficient on-site attenuation can be achieved to ensure other land is not at risk of flooding as a result of the development of the site. 3.9 There are no public rights of way across the site. It is within the control of SLP and there are no known risks of contamination. The site is subject to a planning application and can be released early for housing development. 4. Conclusion 4.1 The Cheltenham Plan performs an important role in terms of delivering the supply of housing to meet the JCS requirements and the requirements for Cheltenham. 4.2 There is a significant shortfall in terms of identified sites to meet the immediate housing needs of Cheltenham. Sites that are currently identified in the Cheltenham Plan, will not boost supply in the short term. 4.3 Including the area identified at Appendix 2 within the Principal Urban Area boundary will enable a contribution to housing delivery in the short term without undermining the objectives of the AONB around Cheltenham. Appendix 1: Site Plan 15 92.9m 2 128 County PEMBRIDGE 122 2 3 140 BRIARBANK RISE Spreads 5 1 10 11 BM 97.57m CARISBROOKE DRIVE 25 8b 23 2 16 CLOSE 104 Collects 8 124 RYEWORTH ROAD 3 9 54 11 60 89.5m 18 28 20 8 4 The Orchards Briarbank House 1 7 148 12 1 15 132 5 2 56 10 Primary School Glenfield 18 HAM CLOSE 1 10 CARISBROOKE DRIVE 4 GLENFALL WAY Job No: 1125 Dwg No: A - P - 100 - 01a Location Plan Scale 1:1250 @ A3 GLENFALL WAY, CHARLTON KINGS CHELTENHAM SEPTEMBER 2016 a Layout amended 20.09.16 ELB Appendix 2: Area to be added to development boundary

21 Mar 2017 13:44
Historic England (Rohan Torkildsen)

Thank you for providing an opportunity to respond to the proposed Preferred Options for the Cheltenham (Part one). We hope our comments will help to support the local authority in its preparation of a sound, robust and effective Local Plan and in so doing secure the delivery of sustainable development.

Historic England note that the scope of Part one of the Plan is limited to the economic strategy for Cheltenham, options for land allocations within the Borough (outside those already set out in the JCS) and proposals for Local Green Space designation. Consequently, whilst the historic environment is a generic consideration for the whole Plan, including Part one, we understand the positive strategy for the conservation of Cheltenham’s historic environment itself will be set out in Part two.

21 Mar 2017 10:05
Ken Pollock

Objections to Cheltenham Plan (Part One): Preferred Options
1
Local Plan's split Stages : an unsound device
Parts One and Two of this Local Plan should be consulted upon together, and should proceed to
Examination together. There is no sound reason (or need) to fix some aspects of the Plan before
interrelated issues are even exposed for consultation.
Tying the JCS down to a UE-only strategy before we knew the huge uplifted-OAN scale was unwise, and
unjust to the small Gloucestershire Green Belt. That 'strategy' was then used inflexibly (for TBC political
reasons) to block a quasi-UE at Highnam, which could provide part-funding for an enhanced river-crossing
connecting to/from Gloucestershire's Forest of Dean district (A48, A40 and A417 converge here on the west
bank).
Following TBC's three months JCS delay, there is now no sound reason not to await the Transport
modelling/mitigation evidence and await this plan's "Part Two" policy proposals (on greenspace, retail
zoning, heritage, etc).
Moreover, until a single integrated Cheltenham local plan is Submitted (and Adopted) it is spineless and
wrong for development control to be proposing the deletion of a raft of Retained 2006 Cheltenham-specific
Policies at/approaching the (preceding) JCS Adoption.
2
Objectives : objections to
Theme A
(b) "Ensure provision of sufficient housing land ..."
This objective needs to be declared "subject to what is sustainably possible", in a town so
super-constrained from expansion as Cheltenham, and moreover a historic "garden town" where
densification at the expense of greenspace and gardens undermines the town's quintessential character.
(h) "Support a network of neighbourhood centres ..."
Therefore we need to retain the Retail 'zoning' policies (strengthening the hierarchy of 'District' and
'Neighbourhood' shopping centres) which were painstakingly established by the 2006 Local Plan.
Theme B
(a) "Ensure provision of sufficient employment land ... to attract new businesses and to enable existing
businesses to grow ..."
The same environmental/heritage constraints (as in Theme A (b) above) need to be stated here, for the
extraordinary and peerless town of Cheltenham.
There is no sense or fairness in mouthing undeliverable/unrealistic Objectives, thereby making resistance to
harmful planning applications more difficult.
(d) "Encourage the delivery of sustainable transport infrastructure, a range of transport options and
better links across the Borough including parking provision and public transport;"
Before focusing on the largely aspirational (arguably unrealistic) aim of favouring 'modal shift', these
Objectives ought to acknowledge that, in a relatively small conurbation (without a tube or a dense bus
network) 80+% of transport movements will be by private vehicle, and these vehicles (which will pollute far
less in future) need the road network to be kept fluent and NOT be degraded (e.g. by inserting bus-lanes
where there is no viable road width).
For soundness, the huge new Allocations need to maintain (and even foster) flow on all their surrounding
routes. This is most essential for the gyratory route around West and NorthWest Cheltenham, linking
Bishops Cleeve to Gloucester and Quedgeley, without seeking to overload the national north-south M5.
4
Employment Sites
E3 - Grovefield Way (6.4 ha)
"provides an opportunity for the establishment of a modern business environment at an important
gateway location"
"planning consent for B1 ... already under construction ... for a high profile car dealership"
Permission for this incursion into the Green Belt, stepping outside the Cheltenham 'outer ring' of Grovefield
Way, was only granted on Appeal; and was for B1 use.
The fact that a "car dealership" has been permitted on part of the site should not mean that the entire site
can simply be assigned away at Plan level to become any B class use, and certainly not 'sui generis'
(meaning a unique, one-off site which can be virtually anything). Why give that away so glibly, when it is
known that this vital section of Cheltenham's limited road network (approaching the double roundabouts
of Arle Court) blocks at peak times?
For example, this is an inappropriate, drive-to-only site for e.g. an isolated supermarket, outside the
defined 'shopping centres'. This site allocation in "Part One" of this plan cannot properly be finalised
before the Retail policies of "Part Two", carrying forward (some of) the Cheltenham-specific Retail Policies
from the 2006 Local Plan, are published for consultation.
Remove E3 from Policy EM3.
5
Local Green Space
Policy GE8A is much preferred;
GE8B is timid and inadequate.
GE8A should be extended (e.g. to anticipate and forestall further development threats to valued
greenspaces).
LGS selections cannot be finalised until we see the proposed carry-forward (in "Part Two") of the extant GE
Policies (from the 2006 Local Plan).
(i) Chargrove (also called 'Greatfield Park')
This prominent greenspace adjoins a developer pre-application site (outside and not supported by the JCS
Main Modifications) to build in the Green Belt on the opposite side of Up Hatherley Way.
Therefore this greenspace needs (and easily merits) the additional protection of LGS designation.
(As a LGS proposal, it may have received less written attention from local residents, due to the perennial
effort required to oppose TBC's disposition to deposit its housing in the adjacent 'Chargrove Triangle', as
done at Farm Lane, Leckhampton.)
(n) Leckhampton
The map in Appendix-G 'LGS Maps' does not extend far enough north, to encompass the key footpath
leading ENE to/from the 'Allenfield' district. This interesting 'rural' section of footpath (of "smallholdings"
character) is an essential part of the figure-of-eight Footpath Loops, which constitute the principal
recreational Amenity value of this intricate landscape.
In advance of fixing the LGS boundary, this plan should be careful not to give developers any hint/basis
upon which to encroach.
In para.178 of her 'Interim Findings' report, the JCS Examination Inspector states:
"taking account of my findings in relation to both the North West Cheltenham and Leckhampton urban
extensions, it might be possible to make a final designation of Local Green Space within the JCS if the JCS
authorities were minded to do so".
Yet now CBC proposes to do nothing before Part Two of this local plan. Instead, CBC should stop working
with Miller-Bovis to push the Leckhampton numbers and footprint well up above 200. Instead, there is
time now, following the (pointless) three months delay to the Main Modifications by TBC, for CBC to agree
a definite LGS boundary at Leckhampton with the Parish Council and Leglag.
Leckhampton was the most elaborately evidenced and earliest proposed LGS application, yet Swindon
Village has managed at JCS stage to reach a dependable definite boundary with its developer.
If CBC still will not amend its past practice and progress the Leckhampton LGS, then the Cheltenham Local
Plan Examination Inspector will have to tell Miller-Bovis where the detailed boundary for development
needs to be. Meanwhile, costly/wasteful planning application re-submissions are likely to occur.
6
Housing Sites
Reeves Field (4.5 ha; 80 units);
"within the Central Conservation Area"
"around 80 dwellings, assuming that around half of the site is retained as green space"
It is outrageous to propose to plunder (for housing numbers, a paltry 80) greenspace lying inside the
Cheltenham Conservation Area, which comprises the best preserved districts of this "most complete
Regency town", essentially a 'garden town'. No review of this Conservation Area boundary has yet been
done.
There was an attempt to reduce the size of the Cheltenham CA about 15 years ago, but it was poorly
evidenced and was defeated.
Visitors leaving the Regency town eastwards on the A40 (Thirlestaine Road) pass some fine buildings
(Cheltenham College Gymnasium, Dewerstone, Thirlestaine Court, Ravensworth, Thirlestaine Hall, Park
House) before meeting Reeves Field and then turning north along the greenspace-lined Old Bath Road.
There is no sense or environmental fairness in proposing the loss of "half" this green space.
Without a detailed plan layout and accompanying reasoning, developers will simply take that developable
'half' as given, as a starting point.
Even agreeing to the principle of losing of this greenspace (and that principle is the major hurdle for any
development) should await the 'outline' planning application stage; unlike for strategic-scale allocations,
there is no need here (for just 80 houses) to plan early (e.g. for major infrastructure).
Leckhampton (15 ha ??; 200 units);
Two hundred units at Leckhampton (especially if Site SD2 at Farm Lane, Leckhampton is not defeated) may
still be found unsound merely due to its cumulative "severe" impact on the vital A46 traffic artery.
Development close to Shurdington Road also needs to respect the key vistas to the Cotswold Escarpment
from the elevated section of the A46 Shurdington Road (between Woodlands Road and Kidnappers Lane).
Arle Nurseries (14.5 ha ??; 200 units);
CBC's 'Arle Nurseries' enables Cheltenham to afford floral displays throughout the town, appropriate to this
Regency garden town.
This economical facility should only be sacrificed if the site is finally removed from the Green Belt.
However, apart from the expediency of some housing numbers, the only essential need for this particular
removal from Green Belt is to permit the "Western Bypass" (the spine road through the new 'West
Cheltenham' allocation) to cross the B4634 and proceed northwards to reach the A4019, at a point east of
Uckington hamlet and west of Holmcroft Drive.
Thus, the eastern apex of the 'Uckington Triangle' (extending westwards to Withybridge Lane) would be
inside the ring road, and arguably become developable.
This desperately-needed highway route ('outer bypass') needs to trigger any development here, NOT vice
versa; and that route desperately needs to be specified and recommended by Gloucestershire's
non-contributing County Highways, with no further delay.
Before Adoption, the JCS Examination should insist that this site be integrated (for transport and other
infrastructure) with the two large housing Allocations to its north and south.
This site is half in Tewkesbury District, and therefore its 'western bypass' element needs comprehensive
specification at JCS level.
It would be grossly inadequate for JCS officers to propose that the 'western bypass' through the Hayden
allocation needs only to be specified piecemeal, i.e. initially just to serve some 'cyber industries' buildings
near Telstar Way, and then subsequently just to reach the B4634 (on an 'at-any-point-will-do' basis).
The entire route from A40 to A4019 needs to be determined in outline at JCS level. Cheltenham must
have a sound transport network for general traffic, (which will always represent 80+% of total traffic).
Arle Gardens (2.1 ha; 70 units);
"playing pitches ... now disused"
As for Reeves Field, there is no need whatsoever (indeed it is poor practice) to pre-grant this greenspace
in a local plan (for a mere 70 units); it should await comprehensive assessment as an outline application.
Nor is there much other greenspace near this one, as the "Part Two" GE Policies can assess properly.
Instead of showing general 'willing' to scrape up small housing numbers within the town (at the expense of
characteristic greenspace), it would be more principled to re-challenge the 5% Uplift in this Local plan, just
in order to spare compact, historic Cheltenham, on the grounds of being by far the most
environmentally-constrained of the three JCS Districts.
7
Mixed Use Sites
Royal Well & Municipal Offices (36 dwellings)
The housing element of this 'site' is negligible (36 units).
Nor is it primarily an Employment site.
Cheltenham BC owns all this land (both the Municipal Offices and the Royal Well bus station) and is seeking
to 'land grab' Royal Well Road for a profitable rearward extension of the Municipal Offices building (Grade
2*) when the Council vacates it shortly.
Currently, Royal Well Road is part of Cheltenham's only ring-road, the two-lane clockwise 'Inner Ring Road'
(IRR), which forms a loop at the northern end of the A46 (Southern Section), from Bath to Cheltenham.
The irresponsible deletion of Cheltenham's IRR is dressed up as the 'Cheltenham Transport Plan', which a
spineless County Highways is implementing to appease Cheltenham's LibDem administration.
Royal Well Road is not (yet) shaded brown (on the plan in 6.8.4), but Royal Well Place is so shaded,
indicating that that road will be deleted for building.
If the bus station can be re-sited (but NOT into the Promenade), then historic Royal Well ought to revert
to greenspace, not become largely a building plot.
8
Conservation Area Review (2016-2018)
"embarked on project to review conservation areas within the Borough in April 2016"
"estimates that all appraisals and management plans will be completed by April 2018"
This CA section of the plan has virtually no content, other than (well-known) outlines of CA principles and a
promise of future work appearing. Yet almost halfway through this two-year 'review project', nothing
has emerged even in Draft for any of the CAs (not for the big Cheltenham one, nor for the six small outlying
ones). Some drafts/indications of this Review's progress need to be published immediately.
"Part Two" ought to manage more substance on this heritage/environment issue, but the above timescale
suggests that will be evaded, by fixing the Local Plan prescriptions before April 2018.
I therefore resubmit my own General and Detailed analysis of Cheltenham's CAs (existing and proposed),
which rebutted the last attempt at CA hacking (in 2000/01).
Cheltenham should be proud to have the largest single CA in the country, comprising almost the entire
Regency town, the most complete anywhere, with all features surviving (from garden villas to artisan
terraces).
Only on its east side does the historic town's built fabric still border greenspace/countryside, which was
previously the 'parkland' of Charlton Park (Grade 2*), which is now St. Edward's School, Cirencester Road.
This 'countryside' running along the east side of Old Bath Road is now (from south to north): Cheltenham
Croquet Club; East Gloucestershire Tennis Club; Reeves Field (playing fields); and Cox's Meadow (water
meadow), the sum of which forms a wholly appropriate setting for this historic leisure town.
Accordingly, these greenspaces are included INSIDE the Cheltenham CA boundary, and must remain so.
In general, greenspaces such as playing-fields (e.g. at Arle Drive) should NOT hasten to declare themselves
redundant at a Plan level, because Cheltenham's JCS housing expansion now demands two new all-through
schools, for one of which there is no obvious site.
An existing school may be enabled to expand, if any smaller 'ancillary' schools/operations currently sharing
its site were able to move out to an available smaller site (e.g. a former playing-field).
The environmental danger is that any 'suddenly needed' "new school" would be used as the Trojan horse
for a further (in itself not small) incursion into Gloucestershire's now much eroded Green Belt.

20 Mar 2017 14:06
Martin Morley

To Cheltenham Borough Councillors

Dear Councillor Willingham

Cheltenham Plan (Part One), Preferred Options Consultation Local Green Space designation for the Benhall side of Gloucester Road

On behalf of 'Save Cheltenham's Trees', I am writing to ask that you reverse the decision made by the panel of officers not to designate "A40 Corridor, Benhall” as a Local Green Space. This request is in response to Question 8 of the current public consultation on the Cheltenham Plan (consultation closing date is 20 March).

Background

The Local Green Space application for 'A40 adjacent to Campden Road and Miserden Road' (a location plan is below) got onto Cheltenham Borough Council's short list of 29 sites in March 2015. This was no surprise as "A40 corridor" was one of the 29 Local Green Spaces approved (out of 10 Local Green Spaces that applied) by an independent report' in January 2015).

 

Local Green Space decision made by the panel of officers in Autumn 2016 

During Autumn 2016, Cheltenham Borough Council's short list of 29 Local Green Spaces were assessed by a panel of officers, who had drawn-up additional Local Green Space criteria, not revealed at the time of the 2014 Local Green Space application period and the 2015 public consultation on the Cheltenham Plan. The selection criteria included a new point of guidance that says: "highway land/roadside verges would not normally be suited for designation". As a result of this "moving the goalposts', the panel decided that "A40 corridor" should not be dedicated because: "The land is adjacent to Highway and may be required for network improvements in the future."

1. Local Green Spaces Study Report (Gloucestershire Rural Community Council, January 2015)

2. Appendix B - Cheltenham Plan Local Green Space Selection Criteria from the "Cheltenham Plan (Part One) 2011 to 2031, Preferred Options Consultation" (Cheltenham Borough Council, January 2016)

3. Appendix C - Local Green Space Site Assessment Table from the "Cheltenham Plan (Part One) 2011 to 2031, Preferred Options Consultation" (Cheltenham Borough Council, January 2016)

In the paragraphs that follow, I set out why "Save Cheltenham's Trees' believe that "A40 corridor" should be designated as a Local Green Space.

a. Cheltenham Borough Council's Green Space Strategy for Cheltenham supports green corridors. "A40 corridor" is clearly a green corridor and Gloucestershire County Council's March 2011 report about A40 Gloucester Road (near Tennyson Road) confirms this.

b. Cheltenham Borough Council's Green Space Audit in November 2008 defined Gloucester Road Open Space on the north (Monkscroft and St. Mark's) side of Gloucester Road as an Amenity Green Space. The Council's report even assigned this Gloucester Road green space in its "High Value / High Quality" category. Why is Cheltenham Borough Council not offering similar protection to the green space on the Benhall side of the A40 that they have already given to the Monkscroft and St Mark's side?

c. Some other authorities are currently designating verges or land adjacent to their main roads as Local Green Space. What is preventing Cheltenham Borough Council from doing the same?

d. "A40 corridor" meets all the National Planning Policy Framework criteria' for Local Green Space designation.

e. The panel of officers have recommended that Chargrove Open Space is to become a Local Green Space, even though it runs directly alongside the busy Up Hatherley Way. This is clearly land adjacent to the Highway, so why here and not beside Gloucester Road? On a similar theme, the panel of officers have recommended that "Land at Pilgrove' is to become a Local Green Space, even though it is directly adjacent to the B4634 Old Gloucester Road / Pilgrove Way junction.

Thank you for taking the time to read this letter. On behalf of the many people who value this Local Green Space (and the thousands of workers, visitors and residents that enjoy looking at this green corridor every day, as they travel along Gloucester Road through Benhall) would be grateful if you would consider challenging the panel decision not designate "A40 corridor" as a Local Green Space and do so before the consultation closing date, 20 March 2017.

 

 

4. Cheltenham Borough Council, Parks, People and Wildlife - A Green Space Strategy for Cheltenham, 2009-2024 (Cheltenham Borough Council, Cabinet 21 July 2009)

5. A40 Gloucester Road (near Tennyson Road) Bus Stop & Pedestrian Refuge, Feasibility Report (March 2011)

6. Cheltenham Borough Council, Green Space Audit (Community First Partnership, November 2008)

7. National Planning Policy Framework criteria for a Local Green Space: "A40 corridor" is in reasonably close proximity to the community it serves, namely Benhall and Campden Road and Miserden Road in particular. "A40 corridor" is demonstrably special to a local community and holds a particular local significance, including its beauty, historic significance, recreational value tranquility and richness of its wildlife. "A40 corridor" is local in character and is not an extensive tract of land. "A40 corridor" does not have planning permission for development. "A40 corridor" is consistent with local planning for sustainable development in the area. "A40 corridor" is not already protected by Green Belt policy or any other designation.

27 Feb 2017 16:54
Newland Homes (Newland Homes)

CHELTENHAM PLAN (PART ONE) 2011 TO 2031 PREFERRED OPTIONS CONSULTATION MARCH 2017 REPRESENTATIONS ON BEHALF OF NEWLAND HOMES LIMITED Cheltenham Plan (part one) 2011 to 2031 Preferred Options Consultation March 2017 Page 2 For Newland Homes Limited 1. Introduction 1.1 Newland Homes Limited (Newland) controls land within Cheltenham Borough at The Reddings (See site Plan at Appendix 1). The site lies wholly within the Green Belt and is partly within the defined Urban Area as set out in the adopted Local Plan that covered the period to 2011. 1.2 These representations focus on the consistency of the Cheltenham Plan’s, policies and proposals with the emerging JCS and national policy and guidance. 2. Consistency with and impact on the JCS 2.1 Newland notes that the emerging Joint Core Strategy (JCS) sets the strategic framework within which the Cheltenham Plan is formulated. 2.2 The JCS has reached the stage where consultation is being undertaken on Proposed Modifications following the Inspector’s Interim Report. Those Proposed Modifications identify a housing requirement for Cheltenham Borough of at least 10,917 dwellings from 2011-2031 (546 dwellings per year) and Policy SD2 plans for 10,997 dwellings. 2.3 The Proposed Modifications also identify that this will be provided within the Cheltenham Borough administrative boundary and cross-boundary urban extensions at North West Cheltenham and West Cheltenham (both of which are partly within Tewkesbury Borough) defined in Policy SA1, and commitments covered by any Memoranda of Agreement. 2.4 In terms of completions and commitments for Cheltenham Borough, those total 3,779 dwellings of which completions comprise 1,426 dwellings. The urban extensions add a further 5,385 dwellings. Windfalls (865) and existing local plan allocation (10) and the Cheltenham Borough Local Plan (957)1 make up the rest of the supply total of 10,996 dwellings, though Newland notes that the Cheltenham plan identifies a total supply of 10,989. 2.5 From the figures above, it is clear that there has been an under supply in the first five years of the plan period (1,426 against a requirement of 2,730) and the level of commitments is less than a five year supply requirement, even without the shortfall being taken into account. Newland notes that the JCS will be using the Liverpool method for managing Housing Supply because of the reliance on delivery from strategic sites, though it is noted that this element of supply is expected from 2017 and there is little chance of this happening. 2.6 Given that the Proposed Modifications has no policy to apply a phased approach to the housing requirement of Cheltenham, it is therefore important in terms of proper 1 All figures taken from JCS Table SP2a as proposed to be modified Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 3 For Newland Homes Limited planning that the Local Plan identifies sufficient sites that have the potential to boost supply in the short term. 2.7 Newland also notes that the JCS Proposed Modification to the Policy SD 6: Green Belt, now includes provision for limited review of the Green Belt through the Borough Plans. 2.8 In terms of the sites allocated in the Cheltenham Plan, Newland notes that only four of those sites, with a capacity of 244 dwellings is projected to be available in the first five years the Plan. Two of these are previously developed and whilst it is noted that they are recorded as being vacant, experience of relying on such sites to deliver according to timescales, in Cheltenham, would suggest a more cautious approach. 2.9 Of the five mixed use sites allocated in the Plan, four are Brownfield and a number have been previously allocated, without coming forward, or subject to un-implementable planning schemes. Whilst it is noted that the sites do not contribute in the first five years, the 200 plus dwellings that these sites contribute to the identified Housing Supply cannot be relied upon. 2.10 From the above, it is clear that additional sites should be identified and allocated in the Cheltenham Plan in order to meet the housing requirement that the JCS relies upon. In order to achieve this, Newland believes that further sites the green belt such as that at the Reddings should be allocated. The following paragraphs set out the reasoning for this site to be allocated. 3. Green Belt Review and justification for allocating site at The Reddings 3.1 As set out above, the Cheltenham Plan as an important role to play in delivering the housing requirements for the Joint Core Strategy. The JCS provides for further green belt review through the Cheltenham Plan. There is also a clear need to boost Housing Supply at Cheltenham in the short term and the allocations identified in the Cheltenham Plan, even if developed as set out in the plan, will not increase the supply by more than half a year. 3.2 The site at The Reddings falls partly within the identified Principal Urban Area as defined by the Cheltenham Plan. Whilst it is within the Green Belt, it is on the edge of that designation. It was considered as part of an omission site during the JCS Examination, however, it fell below the threshold ofr strategic sites, and has not been considered further by the JCS Examination. 3.3 Newland notes that the site has been subject to two Green Belt Assessments with different outcomes. The AERC assessment was for Cheltenham Borough and identified the site as being part of Parcels E2 and E3 which, along with Parcel E1, were accorded average scores in terms of their contribution to Green Belt purposes. Newland also notes that Parcel E1 is being excluded from the Green Belt through the Cheltenham Plan as it is being developed. Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 4 For Newland Homes Limited 3.4 The AMEC Green Belt Review for the JCS placed the site in a larger parcel and accorded it as making a significant contribution to the Green Belt. Whilst understanding that the AMEC review was for strategic purposes, it fundamentally disagrees with the conclusion in relation to The Reddings site, particularly given that the erosion of the Green Belt through the development on Parcel E1 for commercial/retail and employment (located less that 200m from the site) has led to the proposed removal of that site from the Green Belt. Therefore Newland has commissioned an independent review. 3.5 The site is very discretely contained by existing development and its development would not result in ‘sprawl’. Because of its urban fringe location, the site does not form a significant part of the wider rural countryside. The site is situated within already developed areas of settlement, includes agricultural buildings (which Paragraph 89 of the Framework accepts can be redeveloped as long as there is no greater impact on the Green Belt), and is not isolated from the existing residential areas of Cheltenham. It is considered that residential development on this site would have a limited/low risk of encroachment into the countryside. The site is contained within developed boundaries and its development cannot be described as anything other than the infilling of an existing contained parcel of land. It is considered that residential development on this site would have a neutral impact upon the site’s function in preventing coalescence. 3.6 The site is some 4.7 hectares of which 3 hectares is developable and can deliver around 90 dwellings. The agricultural grade of land is moderate (Grade 3) and historically has been used for grazing. 3.7 There are no constraints other than the Green Belt. It is sustainably located with good access to employment and services and good public transport links. 3.8 There is opportunity to set aside and area of the western part of the site as a green buffer, (see Appendix 1). Here significant ecological and landscape improvement can be secured to this currently low value land. The Reddings currently experiences a low level of publically accessible green open space, the inclusion of the western green buffer would create a space for the community to benefit. 3.9 Additionally, the site offers the ability to open up new public pedestrian and bicycle rights of way from Branch Road to Grovefield Way, thereby improving permeability and accessibility for the wider area. There are no historic features, statutory or non-statutory, of acknowledged importance located at or in close proximity to the site. 3.10 The site falls within Flood Zone 1 as identified within the Environment Agency’s latest mapping data. A Flood Risk Assessment and Drainage Strategy have been produced for the site. That work demonstrates development at the site is not at flood risk, it also demonstrates sufficient on-site attenuation can be achieved to ensure other land is not at risk of flooding as a result of the development of the site. Cheltenham Local Plan (Part 1) Preferred Options Consultation March 2017 Page 5 For Newland Homes Limited 3.11 There are no public rights of way across the site. It is within the control of Newland Homes Ltd and there are no known risks of contamination. The current uses do not preclude the early release of the site for housing development and making a policy compliant contribution to much needed affordable housing. 4. Conclusion 4.1 The Cheltenham Plan performs an important role in terms of delivering the supply of housing to meet the JCS requirements and the requirements for Cheltenham. 4.2 There is a significant shortfall in terms of identified sites to meet the immediate housing needs of Cheltenham. Sites that are currently identified in the Cheltenham Plan, will not boost supply in the short term. 4.3 Similar to the strategic housing allocations already identified in the emerging JCS, which are also located within the Green Belt, this smaller allocation put forward as part of the Cheltenham Plan will make a significant contribution to housing delivery in the short term without undermining the objectives of the Greenbelt around Cheltenham.

22 Mar 2017 13:29
Regent Arcade Shopping Centre…

Cheltenham Local Plan - Consultation Feedback
I am writing to provide feedback to the Cheltenham plan as requested in your letter dated 6 February 2017. in our view the proposed plan is inadequate due to a lack of focus and strategy for commercial and in particular retail and leisure activities in and around the town Centre. There is no single reference to the town centre nor has there been any site selection that would prioritise strategic pieces of land within the core retailing boundary capable of supporting mixed use developments aimed at improving the vitality of the town Centre and promoting footfall throughout the day and evening.
I refer to a previous planning application for an out of town development, 15/000321 which was subsequently approved even though it faced considerable opposition. The planning officers argued it was difficult to refuse due to the lack of a local development plan and the absence of a clear policy that promotes a town centre first approach. It was also difficult to assess the impact that out of town developments have on Cheltenham due to the Borough Council's piecemeal approach to relaxing usage. It highlighted the fact there was no strategy for the town centre and therefore no defence against further out of town development.
It is therefore surprising and indeed concerning that despite the planning officer's comments that the proposed local plan appears to go no way towards setting a framework for protecting the town centre over the coming years. It wrongly assumes that the town Centre has fully matured and provides no further opportunities for growth or development.
To reiterate it does not address the issues of ever-growing out of town retail developments and the relaxation of existing space from bulky goods to unrestricted open A1 retail which is a real threat to the future of the town centre. Other areas where policies are vague include; -


- A lack of clear policy regarding public transport which hinders commercial activity within the town
centre and arguably has led to the town Centre not having a defined "heart" due to the volume of traffic running directly through it.
- Locations for stopping buses within the town centre requires rationalisation.
- With no plan encouraging a 'town centre first' approach it will remain difficult to refuse out of town development that continues to threaten the vitality of the town centre.
- There is no reference to tourism and as to what sites or developments could be encouraged to promote visitor numbers to the town.
- Cheltenham continues to fall behind its spa town rivals by not exploiting its heritage and creating new leisure opportunities.
- The town has too many small surface car parks that are difficult to find. These pieces of land could support mixed-use developments with some providing opportunity for larger scale car parks.
- Parking provision needs to be increased to the south and west of the town centre, where most visitors arrive from, the bulk of parking is in the north and east
- Opportunities for park and ride should be considered further to the north and the southeast of the town.

21 Mar 2017 10:19
Next pageLast page