Cheltenham Plan (Part One): Preferred Options

Response Details

Response Details
From David Wilson Homes (- -)
Agent Turley (Andrew Ross)
Date Started: 16 Mar 2017 17:06. Last modified: 16 Mar 2017 17:12
Status Complete
Response ID #528844

Q1

Do you agree with the Vision Themes and Objectives?

  • Yes
  • No

Please enter any additional comments
«No response»

Q2

Do you agree with the Preferred Strategy for the economy? (para 3.16.1)

  • Yes
  • No

Please enter any additional comments
«No response»

Q3

Do you agree with Proposed Policy EM1 Safeguarding Key Existing Employment Land and Buildings? (see also Appendix A, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

Q4

Do you agree with Proposed Policy EM2 Safeguarding Non-Designated Existing Employment Land and Buildings?

  • Yes
  • No

Please enter any additional comments
«No response»

Q5

Do you agree with Proposed Policy EM3 New Employment Allocations? (see also Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

Q6

Do you agree with Proposed Policy EM4 Promoting the Cyber-Security Sector?

  • Yes
  • No

Please enter any additional comments
«No response»

Q7

Do you agree with Proposed Policy EM5 Protecting the Route of the Former Honeybourne Rail Line? (see also Proposals Map)

  • Yes
  • No

Please enter any additional comments
«No response»

Q8

Do you agree with Proposed Policy GE8A or GE8B Local Green Space? (see also Appendix B, C, Proposals Map and site maps)

  • GE8A
  • GE8B

Please enter any additional comments
We support the approach which has sought to ensure that proposed Local Green Space designations are consistent with the criteria set out by national policy (NPPF).

We also agree that the six identified sites that already benefit from strong policy protection would gain no additional planning protections from LGS designation, and so Option GE8B is preferred. This would be in line with NPPG (Paragraph: 011 Reference ID: 37-011-20140306) which identifies that consideration should be given to the additional local benefit that would be gained from designation as Local Green Space.

We support the fact that LGS designation at Leckhampton has "not been considered by the Cheltenham Plan LGS officer panel at this stage" (Para 5.3.5). This would not be appropriate as this area remains subject to consideration as part of the Joint Core Strategy and any specific designation for this area would be premature in respect of the progress to adoption of this plan. On this basis it is not clear that the area should be included at all, even in the indicative way stated and as schematically shown on the proposals map, as this implies a level of consideration that has not been undertake, as identified by the quoted line above.

Whilst David Wilson Homes has previously acknowledged that some areas within Leckhampton may be appropriate for designation as LGS, this is fundamentally on the basis that such a designation should be made only where the full objectively assessed needs for development have already been met, and with consideration given to future development needs. As NPPF Para 76 makes clear "Identifying land as Local Green Space should….be consistent with the local planning of sustainable development and complement investment in sufficient homes, jobs and other essential services. Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the plan period."

Notwithstanding the current findings of the JCS Inspector the 'white land' at Leckhampton has long been recognised as a location that can help to meet local development needs in a sustainable location, outside of the Green Belt. Previous proposals for inclusion of the land in the Green Belt have been resisted on this basis. It is fundamental that where there is significant local development pressure, a finite source of suitable and sustainable locations/land, and where the release of Green Belt land for development is taking place, that full and effective use should be made of non-Green Belt land resources. The suggestion (by the JCS Inspector) that 200 dwellings is the most appropriate quantum for the Leckhampton land (or a ceiling on the capacity of the area), has not been arrived at based on any specific master planning or other specific evidence related to this scale of development. Rather (and acknowledging that the JCS Inspector's finding have been made based on her own observations) the assessments of Landscape sensitivity that have informed this position have been based on a baseline position that excluded development on the Farm Lane (SD2) site, where development of some 370 dwellings is now underway by Redrow Homes. This fact needs to be appropriately taken into account in determining the best use of this land resource, and in turn any potential LGS designation that can be made. Having regard to both the NPPF requirement to only designate LGS in a way that is consistent with planning for sustainable development, and also in a way that ensures designations can endure beyond the end of any plan period. Designation of those parts of the Leckhampton land that were previously allocated by the Council for strategic scale development is unlikely to be compatible with both of the above considerations (as is necessary), notwithstanding the current findings of the JCS Inspector.

Q9

Do you agree with Proposed Policy PR1 Land Allocated for Housing Development? (see also Appendix D, E, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
It is essential that the Cheltenham Local Plan makes provision for the delivery of sufficient housing for Cheltenham over the plan period. This should be informed by the strategic policies that are to be set by the JCS, including recognition that any final housing requirement in the JCS may be expressed as a minimum, the specific contribution that housing development can make to local economic growth and economic performance, and the need to meet (to the fullest extent possible) the significant needs for affordable housing that are evident within the Cheltenham area.

In respect of the Housing figures for Cheltenham that are set out at Table 3 of the consultation document it is not clear from either the document itself or supporting evidence base the basis for the further 865 windfalls that are allowed for in the period to 2031. Whilst this information may have been considered as part of the JCS it is necessary to be clear on the basis of which the Cheltenham housing supply will be secured through this plan, including justification in respect of the various sources of supply. It will also be necessary for either agreed or updated delivery during the plan period from strategic sites to be accurately factored into this table, to inform the residual (minimum) level of development for the Plan Period to be identified by the Cheltenham Local Plan from other sources.
Information is provided on urban capacity within the consultation documents and supporting evidence and we would comment on the following sites at this stage:

Reeves Field (S070) – delivery of approximately 80 units is allowed from this site in 6-10 years (i.e. approximately 2023-2027). This is notwithstanding the fact that the site currently comprises sports pitches and it is acknowledged at 6.5.2 that "The potential loss of sport pitches would need to be justified". Reliance on the delivery of 80 units from this site when the loss of the existing sports pitches is not known to be justified is not sound. This element of the urban capacity should be excluded, as in the absence of suitable evidence and justification it would be contrary to NPPF para 74 and relevant policies of Sport England.

Christ College Site B (S064) – as with Reeves Field above, although this site is said to be disused, its previous/last use was a playing fields (pitches) and therefore in accordance with NNPF Para 74 and relevant policies of Sport England specific evidence and justification is required for the loss of this resource. In the absence of this reliance on capacity of around 70 dwellings from this site would be unsound.

Former Mokscroft Primary School (S093) – as with Reeves Field and Christ College Site B above, this sites previous/last use was a playing fields and therefore in accordance with NNPF Para 74 and relevant policies of Sport England specific evidence and justification is required for the loss of this resource. In the absence of this reliance on capacity of around 60 dwellings from this site would be unsound.

Land at Chester Walk Car Park (S088) – the Council's assessment that "competing demands on the site may rule out housing" does not give convincing evidence that the site will come forward and deliver the 14 units that are anticipated by the Urban Capacity Study.

In the absence of further evidence and justification it would not be sound to rely on these (approximately) 224 units from the Council's Urban Capacity Study, and therefore alternative sources of supply would need to be found. It should also be noted that there are other commitments (such as the planning permission for mixed use development on the former Coach Station Site – S110) that are not robustly justified/evidenced in respect of their future delivery (given that on this particular site an anchor supermarket operator has withdrawn, and planning permission will expire this year) and future iterations of the plan (including evidence base) should robustly corroborate the position on the deliverability of these sites, and this element of the residential capacity within Cheltenham.

We agree with the comment at 6.4.1 that "The existing built up area of Cheltenham is tightly constrained by Green Belt with very little undesignated land in which to expand." It is on this basis that it is essential that, as was previously proposed by the JCS (and other emerging plans before that), the fullest possible use of the undesignated 'white land' at Leckhampton should be made, and/or future sustainable development capacity in this location is not constrained by LGS designation that would not endure beyond the Plan Period (see response to Question 8 above). As noted previously the JCS Inspector's recommendation that a smaller development of around 200 units would be more appropriate has been made without the benefit of specific master planning for this smaller scale scheme, and it is likely that capacity of 300 units, or 400 units (for example) would exist, once detailed proposals are drawn up, having regard to updated landscape sensitivity evidence that specifically accounts for the construction of the Redrow Homes development (370) dwellings on the Farm Lane (SD2) site.

As the Council will be aware David Wilson Homes has an interest in the County Council owned land to the East of Farm Lane as shown on the attached location plan. This forms Site Ref S034 within the Appendix E assessment matrix where only flood risk is listed as a "critical constraint"; this is in contrast to other nearby parcels where landscape sensitivity is noted as being a specific constraint to development. Development on the northern part of this land (SO34) would integrate well with the surrounding urban morphology and ensure that suitable green space is preserved between new development and the AONB to the south, and other local heritage assets, as well as preserving the existing footpath routes across the site and views towards the AONB from them.

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Note

If you know of a site which is suitable for housing and should be included in the Cheltenham Plan please submit information via the Call for Sites form.

Q10

Do you agree with Proposed Policy PR2 Land Allocated for Mixed Use Development? (see also Appendix D, E, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

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Note

If you know of a site which is suitable for mixed use development and should be included in the Cheltenham Plan please submit information via the 'Call for Sites' form.

Q11

Do you agree with the preferred options? (para 7.4.1, see also Appendix F, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

Q12

Do you think that an Article 4 direction to restrict HMOs is required in any part of the Borough?

  • Yes
  • No

If yes then please state where and why
«No response»

Q13

Do you think that an Article 4 direction in any Conservation Area is required to stop the erosion of its special character through householder development in any part of the Borough?

  • Yes
  • No

If yes then please state where and why
«No response»

Q14

Do you think that an Article 4 direction to restrict the loss of office or employment uses to residential is required in any part of the Borough?

  • Yes
  • No

If yes then please state where and why
«No response»

Q15

If you have any comments on the Cheltenham Plan evidence base please enter them below.

It is essential that in respect of the Leckhampton Area the Council has regard to the very latest position on the ground in respect of the implementation of the Redrow Homes development on the Farm Lane (SD2) site and the relative sensitivity of the landscape in this location, and capacity for sustainable housing development outside of the Green Belt.

In addition it is essential that robust evidence is in place to support the expected level of development in the Plan Period from both Urban Capacity and Windfall sites.

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