Revised Core Strategy – relating to Thornbury

Response from Gareth Davies,

Thornbury Resident:

18th February 2011

Introduction:

My initial response to the Revised Core Strategy publication was one of complete dismay. I together with hundreds of Thornbury Residents and others with wider concerns, had painstakingly responded to the draft Core Strategy and Sustainability Appraisal. This was supposedly a period of consultation, when our views and critiques would be used to revise the Strategy, and iron out some of the many glitches and errors and misinformation that had crept into the draft document.

The most striking aspect of the Revision, in relation to Thornbury, is that these Representations have been systematically ignored. Even worse, many of the underlying flaws have been built upon and expanded, to create an even more complex web of inter-related arguments that simply do not stand up to examination. The Thornbury development plans were never based upon transparent and researched evidence. The Sustainability Appraisal never was an appraisal, but simply a belated attempt to rubber-stamp some deals and agreements made behind closed doors, that even at this point in time are still not fully in the public domain, but why else does SGC stick doggedly to a Strategy that just does not add up. Even our own MP, Steve Webb, has voiced his concern about “ the way Park Farm was identified in the first place and about the failure of SGC to amend its plans following the overwhelming local response to the Core Strategy”.

It is with little confidence that I submit for consideration a few of the most striking flaws of the new Revision. Knowing that our views have so far been brushed aside, does not inspire confidence in the next phase of so-called “consultation”. If SGC seriously believes that it has a proud record to defend in terms of consultation, as Patrick Conroy and Peter Jackson have claimed over the last few months, then something is seriously wrong with the guidance being offered to LAs, that is utterly out of kilter with the expectations of the electorate.

My one hope remains not with SGC, who have systematically ignored and failed us, but with the Independent Planning Inspector appointed to examine the Core Strategy and the Sustainability Appraisal. I don’t doubt that he will see through the subterfuge and dishonesty of the process that we have so far been subjected to. I trust he/she will have the courage to declare the Thornbury part as UNSOUND, and require for SGC to start again in its dealings with Thornbury, with a proper analysis of need, and a genuine appraisal of potential sites for development, informed and guided by the knowledge and concerns of the good people of Thornbury, for whom the future of our Town is a matter of utmost importance

I also draw the Independent Inspector’s attention to the good work of Save Thornbury’s Green Heritage (STGH), a group of local residents who have played a vital role in raising awareness and challenging the unsoundness of SGC practise, despite their attempts to engage with planners not coming to fruition. I would urge him/her to consider the merits of the STGH submission, with great care, and invite them for Oral/Public Examination.

The Sustainability Appraisal that doesn’t Appraise:

This Report is clearly misnamed. It was not made available until after Option6/Park Farm was selected as the preferred site for development – it is an attempt to justify a decision that has already been taken, behind closed doors, probably in hand with Barratts, but even then it clearly fails, being littered with unevidenced assumptions, inaccuracies and untruths. Local people with local knowledge were not invited to join in the “appraisal” process, so that a lack of understanding of the true nature of the NW edge of Thornbury is apparent.

  • Unlike the appraisal of all other areas inSouth Glos, the section pertaining to Thornbury has been almost totally re-written in the Revision. Is this because the original version was so flawed? Sadly the flaws continue.
  • Sustainability of the site is based upon the accessibility of the Town Centre. Why, when Public Representations clearly informed SG planners that they had misrepresented the walking distance and accessibility of the site (describing it as a comfortable 15 minute walk), does the Revision continue to be based upon this error. It cannot really be described as an error any more, but rather an attempt to distort and deceive. This misinformation pervades every aspect of the appraisal matrices, meaning that sites are not compared on a fair basis. Even Barratts own Transport Assessment (byFMWConsultancy) posted recently online, which in many other respects bends the truth to present the site in a favourable light, still cites 25 mins as the projected walking distance to the Town Centre. My own calculations, based on real people walking real routes into town, makes Option6 the furthest from town of all the Options. If this is correct, it makes a total nonsense of the whole set of Appraisal Matrices together with the associated ratings.
  • The SA Report claims there are few alternative Brownfield sites within the town – this is not accurate, and reflects a complete lack of either local knowledge or creative thinking.
  • The Park Farm development will require massive infrastructure to service a relatively small housing development – but key existing infrastructure that is already in place along the Morton Way is being ignored. In times of austerity, such a situation should be picked up by the SA, but it is ignored.
  • Many alternative sites/Areas were dismissed very readily, on the basis of a few negative assessments, with no further investigation or genuine appraisal. Each time a negative assessment at Park Farm emerges, it is twisted and distorted and re-invented as a potential positive. A Local Council with an alternative agenda could have just as easily dismissed Park Farm at the “Broad Areas of Search” stage, as they did to Areas C and E. This process has not been driven by appraisal, but by political agendas, hidden from local people.
  • It is claimed the 2006 Independent Inspector, who dismissed Park Farm as the least suitable of all the sites in Thornbury, did not have new evidence that is available to us now. Included in this category of “new information” are

Decline in primary school rolls (But in fact the current decline was well under way in 2006, and in fact is now beginning to bottom out as national birth rates start to rise again.)

Town Centre Vibrancy (But the recent Town Centre Strategy, whilst listing 11 potential actions, nowhere refers to the need for more housing – in fact this is a misinterpretation of the changing nature of shopping habits throughout the UK, that has not been considered by planners.)

Community’s desire to protect land beyond Morton Way. (But this is not in keeping with the evidence generated by a Town Survey by Thornbury Town Council in 2008 which made this site the most popular with local residents.)

CastleSchool’s Aspirations. (But these are so murky and clouded in secrecy and rumour, that even current CastleSchool governors knew nothing of the plans until a private briefing by SG planners on 18-1-11. No public debate, no consultation. Just silence – and then this becoming a driving force for the Revised Strategy for Thornbury.)

  • The Ratings system in the SA matrices is confusing, subjective, and in many cases irreconcilable with statement summaries, making it impossible to make sense of how ratings have been awarded, or to use them as a tool for measuring the appraisal process.
  • The role of Tesco in the lives of local residents, has been ignored by the SA – despite Representations advising of this shortcoming.

Decline in Town Vitality:

Several pages of the Revision of the SA Report make much of the decline of Thornbury over recent years and state this as evidence of the need for more housing to regenerate our Town.

  • There is no evidence that more houses will impact upon footfall in local shops
  • There is a lack of understanding of the development of our town over the last 40 years. A closer reading of the statistics suggests that the town is not so much in decline, but pretty much on a par with towns of a similar nature elsewhere. Conclusion – Thornbury was a “youthful” town when it was rapidly expanding – hence the need for so many Primary Schools. Now we are reverting to a “norm” and need to respond appropriately – not artificially recreating the past with another building boom that brings the “Bradley Stoke factor” to Thornbury.

The Problems with Park Farm:

  • It is too far from the town centre to walk (and even further to Tesco)
  • It forms a logical edge between the town and the countryside of the Severn vale (a defensible boundary formed by the strong physical barrier of Thornbury Castle/Shieling School/Castle School/ Medieval Fishponds/ ListedBuildings)
  • It is too close to some of the main historic sites in Thornbury – the Castle, St Mary’s Church, the mediaeval fishponds, listed buildings – and it would irrevocably destroy an ancient deer park. Shocking that the Heritage Reports commissioned by Barratts, (who are obviously the paying customer, specifying what they are requiring), which have just gone on line ONE DAY before the deadline for this submission, go into great lengths to describe some of the delightful heritage of these fields and buildings, but then effectively dismiss them as not really worth hanging on to! Thankfully there are still some in Thornbury who value its surviving heritage.
  • The flood risk pushes most possible development to the north of the site, which is further still from the town centre
  • It contains a wide selection of Biodiversity Action Plan priority protected species – that are virtually ignored in the SA.
  • It would require major infrastructure development at a time of national austerity (particularly when there is unused infrastructure that could support development in other parts of Thornbury).
  • It contains mainly Grade 2 or 3a agricultural land.
  • Access via Butt Lane will exacerbate already serious traffic problems.

The Medieval Fishponds.

I am astounded that more is not made of this delightful historical treasure on the NW fringes of Thornbury, and inextricably linked with the histories of ThornburyCastle. To propose a housing development that will completely surround the Fishponds is an act of vandalism on the part of SGC. English Heritage commented on the inappropriateness of this proposed development in its Representation back in August. A local “Friends of The Medieval Fishponds” has recently emerged in an effort to raise its profile and afford it greater protection. The Ecology and Biodiversity of the area has been understated and in many cases ignored by the SA, despite opportunities to incorporate this information in its Revisions. The delicate eco-system will likely be overrun by its use as a “playground” once surrounded by dense housing. The ponds are spring fed, and could be irreversibly damaged by building developments. – and no adequate investigations/research. Why is this site even being contemplated for development, when the evidence for Thornbury’s need for more housing is not proven, and when alternative, including Brownfield sites, offer much more Sustainable credentials?

Conclusion:

The Core Strategy will set the framework for housing development through to 2026. It needs to be based on a sound foundation of evidence which stands up to close scrutiny. The preferred location for Thornbury does not meet this requirement, and should be withdrawn from the Core Strategy, and an alternative plan produced in conjunction with Thornbury’s residents.