Objection to Policy A7 – South Cheltenham – Up Hatherley Urban Extension, Cheltenham

I strongly object to the allocation of approximately 795 dwellings at Up Hatherley given the location of the site within a highly sensitive area of Green Belt which is critical to the separation of Cheltenham and Gloucester.

Further, I strongly object to the way in which this site has been put forward now for development in the Joint Core Strategy (JCS) at this later stage of the plan making process when it did not feature in any of the development scenarios included in the ‘Developing the Preferred Option Consultation Document’ published in December 2011.

The development scenarios in the Developing the Preferred Option document (DPO) covered a range of housing requirements from 33,200 to 40,500 new homes, along with a range of employment land requirements. South Cheltenham only appears as a potential broad location for development, along with a number of other locations around Cheltenham, Gloucester and Tewkesbury, as a possible option to help make up the deficit in housing numbers projected in the various development scenariosafter 2021. However in doing so the DPO also recognises that any shortfalls are to be addressed through specific themes, which include protecting the Green Belt to prevent the coalescence of Gloucester and Cheltenham.

The current draft JCS is proposing a level of housing growth over the Plan period at the lower end of the range, ie. 32,000 dwellings. Given the circumstances outlined above it is highly disingenuous and without justification to bring forward the allocation of land south of Cheltenham for development. The plan making process has to proceed with transparency and credibility, and local communities need to have trust in it. The introduction of the Policy A7 site in the JCS without prior warning can only be perceived as a ‘last minute’ switch from allocating land elsewhere, and this has done nothing other than to seriously harm the public’s perception of and belief in theplanning process.

The National Planning Policy Framework (NPPF) requires local planning authorities to ensure that Local Plans are based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of their areas (para. 158). A Local Plan will only be found ‘sound’ if the plan is the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence (para. 182).

It isunquestionably clear that the JCS’s strategy for housing growth around Cheltenham does not take full and proper account of the AMEC JCS Green Belt

Assessment report (2011) which is a key component of the evidence base underpinning the Core Strategy.

The Policy A7 site is identified as Segment SE4 in the JCS Green Belt Assessment report. This area forms part of a cluster of segments which make a ‘significant contribution’ to the Green Belt. Paragraph 5.2.6 of the report explains that the contribution of these segments to the prevention of the merging of Cheltenham and Gloucester, the main purpose of designation, is very clear, as is their role in prevention of sprawl. The report thoroughly and objectively assesses Segment SE4 against the five purposes of Green Belts and concludes that the land:

  • Makes a significant contribution to checking the unrestricted sprawl of large built-up areas, as the Green Belt here forms a clear southern boundary to Up Hatherley preventing ribbon development along Up Hatherley and Shurdington Road.
  • Makes a significant contribution to preventing nearby towns from merging into one another in that it limits the joining of Leckhampton and Shurdington, thus separating Cheltenham and Gloucester.
  • Makes a significant contribution to assisting in safeguarding the countryside from encroachment, as the Green Belt here forms a clear southerly boundary to recent development at Up Hatherley, which is well defined by the boundary of Up Hatherley Way preventing encroachment.
  • Makes a contribution towards preserving the setting and special character of Cheltenham.

The JCS Green Belt Assessment report stresses that there needs to be very careful consideration of other evidence before any of the segments making a significant contribution to the Green Belt are considered for release from the Green Belt. These segments play a key role in the separation of Cheltenham and Gloucester, the original purpose of designation (para. 5.6.1).

The report’s recommendation for the cluster of segments including SE4 to the south of Cheltenham is clear:

“This area is critical to the separation of Cheltenham and Gloucester, being the original purpose of Green Belt designation” (my emphasis).

The Government’s stance in respect of the Green Belts is well known. It attaches great importance to Green Belts, and the NPPF explains that it is the

fundamental aim of Green Belt policy to prevent urban sprawl by keeping land permanently open. Further, the essential characteristics of Green Belts are their openness and their permanence (para. 79). The NPPF also states that once established, Green Belt boundaries should only be altered in exceptional circumstances.

In view of the Government’s position concerning the protection of Green Belts and the objective evidence put forward in the JCS Green Belt Assessment report that the Policy A7 site is situated in an area that is critical to the separation of Cheltenham and Gloucester, the JCS Councils have not justified the allocation of the site for housing as part of its strategy for growth. Accordingly the draft JCS is not ‘sound’ as required by NPPF para. 182.

The Policy A7 site is open countryside separated from the southern urban edge of Cheltenham by Up Hatherley Way and the A46 Shurdington Road. These major roads provide strong defensible boundaries to the Green Belt and their effectiveness is plain to see both in immediate view points and from the higher Cotswold escarpment. The development of the site would constitute irrational, ill-judged encroachment on the countryside and the Green Belt which would be fundamentally at odds with the recommendations in the JCS Green Belt Assessment report.

There is no evidence that the JCS Councils have thoroughly examined all other options to accommodate this housing development. It may be the case that some Green Belt land has to come forward for development in the longer term, however there are other potential options further west towards the A40 Golden Valley Bypass. Here planning permission has been granted for major employment development adjacent to the Park and Ride facility which, together with other ribbon development and strong boundaries provided by existing major roads, presents a more logical location for the consideration of further housing development.

Overall the Policy A7 site is an ill-considered and irrational addition to the JCS’s evolving development strategy. The need for additional housing around the major settlements of Cheltenham, Gloucester and Tewkesbury does not in any way justify the ‘quick fix’ manner in which this site has been allocated. It is simply unacceptable to foist substantial new development on a local community in a way that clearly betrays a lack of thorough examination of the evidence and appraisal of all of the options.

There are other, well documented concerns about the development of the Policy A7 site, including the impact on local roads and on schools. There is no point in having a development plan without a proper understanding as to how infrastructure needs are going to be met. The A46 is already a heavily used commuter route with lengthy queues of traffic at peak times. The excessive volume of traffic has nothing but a detrimental impact on residents living along this road, yet the plan is to direct all traffic from the A7 site onto the A46. This seemingly lack of a proper understanding of the impacts of development on local infrastructure is also reflected in the consideration of local secondary school capacity. Both local secondary schools – Bournside and Balcarras – are now academies meaning that they have autonomy when it comes to decisions about providing further capacity. It appears that the JCS Councils are relying on an exercise of assessment of impacts on local infrastructure/services after site allocations are made by which time it is too late if sufficient mitigation cannot be secured. The JCS is therefore not being positively prepared as required by NPPF para. 182.

For the above reasons I strongly object to the inclusion of the Policy A7 site within the JCS, and respectfully ask that it is removed from the Plan.

Amanda Winstone

7 Aldershaw Close

Up Hatherley

Cheltenham

GL51 3TP