Cheltenham Plan (Part One): Preferred Options

Response Details

Response Details
From Newbridge Construction Limited…
Agent Deleted User
Date Started: 20 Mar 2017 17:10. Last modified: 30 Mar 2017 12:05
Status Complete
Response ID #529537

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
«No response»

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
[see attachment]

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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.

«No response»

Additional text

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.